It is the aim of the State Government, in accordance with the guidelines outlined in the Third Malaysia Plan (1976-1981) to the present Seventh Malaysia Plan (1996-2000) which emphasised increase integration of environmental consideration into sectoral and socio-economic development, to achieve a sound and sustainable development. However, the current status of environmental management in Sabah is still seen as fragmented and lack of co-ordination between departments.

4.1. Natural Resources

Sabah’s coastal zone contains a wide range of different natural habitats, which reflect the great biodiversity of Borneo. Some of these habitats have remained in a pristine state with very little change but in some areas, due to natural and human factors, the natural habitats have been disturbed by rapid development.

During the preparation of the Sabah Coastal Zone Profile in Phase 1 of the ICZM project, definition and classification of the habitats in the Sabah’s coastal zone have been undertaken. These areas have been classified in a structured manner, which allows both an understanding of the inter-relationships between the physical characteristics and the biota in the ecosystem. This habitat classification is unique to Sabah, but is based on the proven system of Wetlands Classification developed by the US Fish and Wildlife Service [5]. In most of this classification, the major factor that influences changes between habitats is water. The water quality and its transitional state (whether flowing, still, seasonal, or absent) helps to define the differences of wetland habitats. These differences are primarily demonstrated by the change in the plant cover in an area, which in turn is usually most dependent on the substrate, water regime and climatic variation.

The classification of coastal wetland habitats starts with a primary division into five Systems: Marine, Estuarine, Riverine, Lacustrine, and Palustrine; and all other habitats fall into the Terrestrial System [6]. These Systems define the broad spatial areas characterised by the major differences in flora and fauna found within each system. In the first five ecosystems, it is the nature of the water regime that defines these systems.

The Habitat Map provides an illustration of the coastal habitats of Sabah [7]. The habitats that were mapped for the marine ecosystem are the continental shelf, islands, and reef. For the estuarine system, the coastal areas that were mapped were the channels and forested wetland. The rivers in the palustrine system were well illustrated in the Habitat Map. For the palustrine system, peat swamps are shown and, inland, the lowland dipterocarp forest are mapped.

The present Habitat Map can be considered as the first attempt at mapping the coastal habitats of Sabah; it is not the definitive map for the current extent and status of coastal resources of the State for various reasons [8]. Firstly, a systematic survey of the coastal zone, particularly the marine and estuarine systems, has not been done. Some important habitats have no available data such as the seagrass beds and rocky shores. Secondly, the available data on the extent, status, and current uses of various habitats have not been readily available or are available but have yet to be incorporated in the GIS database. For example, the coral reefs fringe the coast of Sabah but the locations of good or damaged reefs are not shown. The mangrove forests are also shown in the Habitat Map but the portions of the forest that were converted to agricultural land have yet to be shown. Thus, the Habitat Map shows a greater cover of mangrove forest than it is on the ground. Likewise, the lowland dipterocarp forest, the areas of forest that were converted to agricultural lands are still shown in the Habitat Map as pristine forest.

Mangrove forests, seagrass beds, and coral reefs are some of the important ecosystems along the coastline. These ecosystems provide habitats and feeding ground of many species, some of which are exploited for food. In the mangrove fisher folks are harvesting forests, crabs, and some fishes. Furthermore, seagrass important habitats for young fishes and invertebrates and the feeding grounds of endangered species like the sea cow ( Dugong dugong ). On coral reefs, numerous species of fishes are exploited for food, most notable of these are the groupers, snappers, and emperors that are caught and sold live in Kota Kinabalu and Hong Kong. Furthermore, populations of coral reef fishes, because of their attractive, bright colours, have the potential to be exploited for the lucrative market of aquarium fishes. Mangrove forests and seagrass beds are nursery areas for fishes and shrimps. These coastal ecosystems are indeed important to conserve for the protection of endangered species, for sustainable fisheries, and for continuous growth of commerce.

These coastal ecosystems are threatened by human activities. Clearing of mangrove forests for pond culture of fishes and/or shrimps, for residential areas, and for commercial centres are some of the threats to this ecosystem. Excessive sedimentation from land, resulting from logging, construction, clearing of mangrove forests reduces seagrass beds by stunting growth or by completely burying the seagrass bed. Reclamation of land on the coast eliminate completely and directly areas of seagrass beds or coral reefs. In the process of reclamation, nearby coral reefs may be slowly be affected by sediment that is carried away from the reclamation site by currents. Organic pollution from land through rivers causes eutrophication that ultimately leads to the smothering of coral reefs. Fishing activities could be damaging to the habitats when destructive fishing gears, both legal and illegal, are used. For example, trawling, a legalised fishing gear, disturb the seafloor while fish bombing, an illegal method of fishing, lead to the destruction of coral colonies. These threats to the coastal resources in the mangrove forests, seagrass beds, and coral reefs compound the impact of over fishing on coastal resources.

Over fishing and destruction threaten these coastal habitats and the resources living in them. The threats are multifaceted and so an integrated approach is necessary. For this approach to be feasible, the location, extent, and status of these habitats are needed. In addition, it is important to define which of these threats is paramount in a locality. Only then can an appropriate intervention be defined for either conservation of habitats, protection of biodiversity, or management of renewable resources.

4.2. Environmental Management Framework in Sabah

The environmental management framework in Sabah follows that of the national framework and is categorised into international, national and state level. Since a detailed description of each of the management framework is beyond the scope of this report, only a few of the strategies and policies have been described in detailed while others are only listed and further reference is provided in the reference section.

4.2.1. International Treaties

a) Convention on Biological Diversity 1992 (Rio de Janeiro)

Rio Declaration on Environment and Development (27 Principles)

The United Nations Conference on Environment and Development was held in Rio de Janeiro in 1992. Heads of State, their representatives and other national delegates agreed on a non-binding Declaration on Environment and Development, known as the Rio Declaration. The relevant environmental principles outlined there are:

Principle 4

In order to achieve sustainable development, environmental protection shall constitute an integral part of the development process and cannot be considered in isolation from it.

Principle 10

Environmental issues are best handled with the participation of all concerned citizens, at the relevant level. At the national level, each individual shall have appropriate access to information concerning the environment that is held by public authorities, including information on hazardous materials and activities in their communities, and the opportunity to participate in decision-making process. States shall facilitate and encourage public awareness and participation by making information widely available. Effective access to judicial and administrative proceedings, including redress and remedy, shall be provided.

Principle 11

States shall enact effective environmental legislation. Environmental standards, management objectives and priorities should reflect the environmental and development context to which they apply. Standards applied by some countries may be inappropriate and of unwarranted economic and social cost to other countries, particularly developing countries.

Principle 15

In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.

Principle 16

National authorities should endeavour to promote the internalisation of environmental costs and the use of economic instruments, taking into account the approach that the polluter should, in principle, bear the cost of pollution, with due regard to the public interest and without distorting international trade and investment.

Principle 17

Environment impact assessment, as a national instrument, shall be undertaken for proposed activities that are likely to have a significant adverse impact on the environment and are subject to a decision of a competent national authority.

b) Agenda 21

Following the United Nations Conference on Environment and Development mentioned above, a much fuller document was produced, setting out an agendum for actions during the 21 st century. Known as Agenda 21, it contains much material relevant to Integrated Coastal Zone Management. Amongst the relevant chapters are the following:

Chapter 9

This chapter deals with protection of the atmosphere, which is a broad and multi-dimensional endeavour involving various sectors of economic activities. The protection of the atmosphere programmes include addressing the uncertainties (improving the scientific basis for decision-making), promoting sustainable development, preventing stratospheric ozone depletion and trans-boundary atmospheric pollution.

Chapter 10

The integrated approach to the planning and management of land resources deals with the reorganisation and where necessary, strengthening of the decision-making structure, including existing policies, planning and management procedures and methods that can assist in putting in place an integrated approach to land resources.

Chapter 11

In efforts to combat deforestation, there are four programme areas involved. The programme areas are:

  1. Sustaining the multiple roles and functions of all types of forests, forest lands and woodlands.
  2. Enhancing the protection, sustainable management and conservation of all forests, and the greening of degraded areas, through forest rehabilitation, afforestation, reforestation and other rehabilitative means.
  3. Promoting efficient utilisation and assessment to recover the full valuation of the goods and services provided by forests, forestlands and woodlands.
  4. Establishing and/or strengthening capacities for the planning, assessment and systematic observations of forests and related programmes, projects and activities, including commercial trade and processes.

Chapter 15

The objectives and activities of this chapter of Agenda 21 are intended to improve the conservation of biological diversity and the sustainable use of biological resources, as well as to support the Convention on Biological Diversity. The programme area is conservation of biological diversity.

Chapter 17

This chapter deals with the protection of the oceans, all kinds of seas, including enclosed and semi-enclosed seas, and coastal areas and the protection, rational use and development of their living resources. Programme areas include integrated management and sustainable development of coastal and marine areas including exclusive economic zones, marine environmental protection, sustainable use and conservation of marine living resources of the high seas, sustainable use and conservation of marine living resources under national jurisdiction, addressing critical uncertainties for the management of the marine environment and climate change, strengthening international including regional co-operation and co-ordination, and sustainable development of small islands.

Chapter 18

This chapter deals with the protection of the quality and supply of freshwater resources: application of integrated approaches to the development, management and use of water resources. The programmes proposed for the freshwater sector include integrated water resources development and management, water resources assessment, protection of water resources, water quality and aquatic ecosystems, drinking-water supply and sanitation, water and sustainable urban development; water for sustainable food production and rural development, and also impacts of climate change on water resources.

Other international treaties applicable to Sabah are:

c) Langkawi Declaration of Environment 1992

d) Convention on Climate Change 1993

e) International Tropical Timber Agreement (ITTA) 1983

4.2.2. National Level

At the national level, the list of several environmental management frameworks has been outlined. These are:

a) Malaysian National Conservation Strategy 1992

This conservation strategies was intended to set out plans and suggestions to be used to:

b) National Policy on Biological Biodiversity 1998

This policy is formulated with the aim to conserve Malaysia’s biological diversity and to ensure that its components are utilised in a sustainable manner for the continued progress and socio-economic development of the nation. This policy has outlined six objectives to be achieved through the eleven outlined policy principles.

c) National Environmental Policies (Draft) 1998

4.2.3. State Level

At the State Level, there are several environmental frameworks that have been in used in Sabah, they are:

a) Sabah Conservation Strategy 1992

The Sabah Conservation Strategy was prepared under the auspices of the then Ministry of Tourism and Environmental Development (now the Ministry of Tourism Development, Environment, Science and Technology). The three volumes provide a thorough guide to environmental policies and actions relevant to the environment. The document outlined several recommended strategies with regards to environment, which are given in much greater detail in the original document. The recommended policies are grouped here under Land Policy, Water and Coastal Policy, Forest Policy.

Land Policy

These recommendations are based on intensive consultation between all levels of government, and long experience in management of the environment in Sabah. Together, they would provide a great strengthening of Sabah's land management and a reduction in the impacts of land use in the coastal zone.

Action Strategy 1: Institutional Strengthening

There must be an upgrading of the capacity of the State Government to manage allocation of natural resources and the natural environment generally, and to protect environmental quality.

Action Strategy 2: Land Allocation and Management

Guidelines for land allocation

a) Government agencies involved in the processes of land allocation must recognise the problems associated with the now-typical patterns of rural land use in Sabah, and guidelines provided in the Sabah Conservation Strategy should be followed.

Land reservation

  1. Land, which is unsuitable or of limited suitability for permanent agriculture, and which is likely to become degraded or idle if deforested, will be reserved by Government.
  2. Government will reserve land, which is subject to competing, and difficult-to-resolve claims.
  3. Priority must be given to halting unnecessary deforestation on ridge tops and hill tops which occur on State land and alienated land.
  4. Adequate land under natural forest will be reserved in rural areas for exclusive use by local communities for purposes of obtaining traditional forest products.
  5. Rural communities whose members wish to continue to cultivate hill rice (i.e. to practise stable shifting agriculture) will be allocated specific, communally managed land areas which will be reserved for this purpose.

Land alienation

  1. Government will make efforts to reduce the confusion and abuse which has arisen from the liberal system of land distribution.
  2. State land will be alienated for agriculture only if the land is truly suitable for permanent agriculture and likely to be developed and well managed. State land should not be alienated for agriculture on the basis of native customary rights alone.
  3. Where land which is unsuitable or of limited suitability for permanent agriculture has been alienated or has been approved for alienation, every effort will be made to prevent degradation of the land.
  4. Government will entertain applications for land to be retained under natural forest cover, either entirely or partially, up to a maximum of 50 acres per holding, for purposes of sustainable wood production, rattan production, Eco-tourism, or other purposes which can be justified by the applicant.


  1. Prevailing levels and extent of soil erosion in Sabah must be greatly reduced.

Slope limits

  1. Future alienation for agriculture of land mainly or entirely above 25 0 slope will be prohibited.
  2. Government will adopt and announce a policy that land above 25 0 slope is not recommended for agriculture. Furthermore that all existing conditions of land title whereby alienated land which is still not developed will be waived for land above 25 0 slope.

Sloping agricultural land technology (SALT)

  1. SALT will be promoted by all Government agencies involved in use of land of greater than about 15 0 slope for agricultural, agro-forestry or animal husbandry purposes.

Idle land

  1. Alienated land which is clearly idle (i.e. predominantly under scrub or grass which is not used as grazing land, but not land under regenerating natural forest) will continue to be subject to fines for non-fulfilment of land title conditions.

Plantation forests

  1. The development of plantation forests will be carried out with the following concurrent objectives to support the goal of reducing levels of timber cut in natural forests:
  1. Existing plans to convert Forest Reserves to plantation forests will be abandoned and, instead, means and incentives will be provided to utilise alienated land and any deforested land, which is of limited suitability for agriculture, for wood production through plantation forests.
  2. New proposals for plantation forests within Forests Reserves may be generated for sites which were severely degraded through logging and fire prior to 1992, subject to a process of justification and objection.


  1. Government will assist the Lands and Surveys Department to develop a central database on land applications, land ownership and land use.

Action Strategy 11: Environmental Planning and Management Procedures

Land use plans generated on a regional or District basis will form the basis for land allocation in all rural areas throughout Sabah. Guidelines must be developed rapidly and used to aid decision-making on land allocation.

Land which has been reserved by law for protection or management of natural resources (e.g. Forest Reserve, Park, Nature Reserve, and water supply area) must be surveyed and demarcated on the ground in a way that will be recognised in a court of law. The potential for use of remote sensing and Environmental Impact Assessments in planning should be more fully explored and utilised.

Water and Coastal Policy

The following recommendations would strengthen Integrated Coastal Zone Management through a combination of safeguarding catchment areas, improving water quality and supply in the coastal zone, and reducing impacts of polluted flows into marine areas.

Action Strategy 3: Conservation of Freshwater Resources


  1. The needs associated with the protection of freshwater supplies will be given priority over all other sectors when allocating land and making decisions on activities that affect land.

Water catchment areas

  1. Important water catchment areas will be identified on a state-wide basis and given adequate statutory protection.
  2. Responsibility for management of each important water catchment area, including implementation of protective measures, will lie with the relevant agency.

Edges of watercourses

  1. The banks of watercourses must be protected to minimise erosion and to limit entry of human-generated pollutants.
  2. Retention of riverine reserves, following the guidelines already used by Government, will be strictly observed during land alienation and development processes. Riverine reserves should always be marked both on the title or lease and on the ground during the survey.
  3. Reserves of at least 100 m must be retained along sections of large rivers, which are clearly, and naturally changing course, except where either existing land titles or well-established, long-standing native customary rights are held.

Freshwater fish

  1. Natural freshwater fisheries will be conserved by protecting the freshwater and estuarine environment, and by taking steps to identify and reduce main sources of pollutants. Natural waterways will be ‘restocked’ only with native fish species unless there are special reasons to do otherwise in particular circumstances.

Hydro-electric power (HEP)

  1. The development of HEP in Sabah should proceed, but with priority given projects which result in inundation of small land areas which can be shown to be unimportant for biodiversity conservation, and which cause minimal disruption of human communities.
  2. All HEP proposals will be subjected to Environmental Impact Assessment.

Action Strategy 6: Management of Coastal and Marine Resources

Mangrove and nipah forests will be managed integrally and sustainably for both fisheries and forest products, with priority given to fisheries. There will be a reduction in trawling as a method of fishing in inshore waters. Continued efforts will be made to reduce the amount of illegal bombing and all forms of damage to coral reefs.

Forest Policy

The following recommendations would help to maintain the integrity of forested areas, reduce erosion, safeguard water quality, and improve economic sustainability in the coastal zone.

Action Strategy 4: Conservation of Natural Forests

The management of natural forests must be based primarily on their protective functions (especially relating to water, biodiversity and prevention of adverse off-site effects likely to result from severe disturbance) and secondarily on their productive functions (including products other than timber).

The rationale for the wood production component of natural forest management must rapidly become the annual harvesting of volumes of wood which are sustainable in the long-term, and not the supply of revenue to the State Government.

Natural forest conservation will be tackled primarily through (a) prevention of unnecessary deforestation, (b) improved management of all natural forests, and (c) increased allocation and use of land outside existing reserved forests for forest-based purposes.

Natural forest cover should be maintained on all land except where specific areas are likely to be used more productively, and without significant adverse environmental effects, under alternative uses. Special attention must be given to maintaining the integrity of reserved forests. Precedents must not be allowed to be set which will permit uncontrollable long-term encroachment and degradation. Government should facilitate public support for the Sabah Forestry Department’s ongoing efforts to stop illegal logging.

Levels of logging damage must be reduced by implementing (short-term) financial penalties on licence-holders, based on actual amounts of damage done during logging and (long-term) a new system of awarding logging licences which improves the incentive for licence-holders to minimise damage.

Action Strategy 5: Conservation of Biodiversity

The fullest possible array of Sabah’s natural biodiversity must be conserved in situ.

As a long-term goal, at least 10% of Sabah’s land area must be retained as totally protected forest habitat and the total extent of natural forest should never be reduced to less than 50% of the land area.

Support will also be given, especially to the Department of Agriculture, Sabah Forestry Department and Wildlife Department, for ex situ protection of biodiversity.

Action Strategy 10: Support for Development of Forest-based Industry

Efforts to develop a sustainable, integrated forest-based industry in Sabah must be broadened and accelerated, but the wood requirements of the industry must be very much less than is presently the case.

Activities carried out to support forest-based industry must always support sustainable management of natural forests. Natural forests (including secondary and degraded forests) will be managed for wood and rattan production wherever possible in preference to clearance and replacement with plantation forests.

Action Strategy 12: Prevention of Forest Fires

Concerted efforts must be made to prevent forest fires, whether localised or widespread.

b) Sabah Tourism Master Plan 1996

Tourism in Sabah is very much influenced by the management issues of natural resources. Therefore, the Natural Resource Policy was an important consideration in the preparation of the Sabah Tourism Master Plan 1996, in accordance with the Malaysian Natural Resource Policy outlined in the 6 th Malaysia Plan (1991-1995). This policy is aimed to:

Sabah Biodiversity Conservation Project 1998

This project is intended to identify potentially protected areas for conservation.

4.3. Land Use Planning

4.3.1. Land Capability Classification

The Land capability classification [9] gives the relative economic capability of the land for its inherent natural resources and arranged in order of general utility equivalent to an economic land use classification. Thus Land capability classes, the various natural resource groups are interpreted into five Land capability classes in decreasing importance with Class I having the greatest theoretical alternative uses but always giving the highest on development and Class V with the least uses.

Land Capability Class I

High potential for mineral development and therefore best suited to mining.

Land Capability Class II

High potential for agriculture with a wide range of crops and is therefore best suited for a diversified form of agriculture.

Land Capability Class III

Moderate potential for agricultural with a restricted range of crops and therefore best suited for a limited variety of crops with a high level of soil tolerance.

Land Capability Class IV

Has a potential for forest resource exploitation and best suited for this purpose?

Land Capability Class V

Has no potential for forest exploitation and best suited for hydrological or wildlife purposes.

As can be seen in the above classification, from development planning standpoint, the land capability classes do not include environmental consideration thus environmental consideration is omitted.

4.3.2. Spatial Planning

Land Use Zoning

The present planning authorities in Sabah are of 3 levels. The highest level is the Governor of Sabah (TYT Yang di Pertua Negeri), the second level of authority is vested in the Central Town and Country Planning Board (chaired by the Permanent Secretary of the Ministry of Local Government and Housing) while the first level is the Local Authority. The Department of Town and Regional Planning serves only as a Technical Advisor to the Local Authority and a Secretariat to the Central Town and Country Planning Board as accorded under the Town and Country Planning Ordinance (Cap 141), but has no authority on planning matters under this ordinance.

Land-use zoning is used in all planning schemes (Local Plan, District land-use Plan and Town Plans) to guide and control development. The current process and procedures of plan preparation practice in Sabah is summarised in the following successive steps.

Process within the Department of Town and Regional Planning

  1. Preparation of Drafts Scheme after a resolution is passed by the Local Authority.

As soon as a Local Authority has passed a resolution to prepare a Drafts Scheme, it will inform the department to prepare such Draft Schemes. The Draft Scheme may be called a Draft Planning Scheme or a Draft Local Plan. The process of preparing the Draft Scheme involves the following stages: -

  1. Research

Before the Draft Scheme is prepared, the Research Unit of the Department will conduct the following studies:

Based on the results of the studies by the Research Unit, a report will be prepared and passed on to the Local Plan Unit to serve as a guide in preparing the Draft Scheme.

  1. Drawing the Plan

The Local Plan Unit will then draw up the Draft Scheme based on the report from the Research Unit. The Draft Plan will set out overall desired broad framework or its area and indicating the basic allocation of zoning/landuse and human activities and transport network to serve these areas.

  1. Submission of the Draft Scheme to Local Authority

Once the Draft Plan is completed, it will be sent to the Local Authority for adoption, publication and put out for public examination and objection.

Process outside the Department of Town and Regional Planning

  1. Submission to the Central Town and Country Planning Board

After consideration of all objections to the Draft Plan, the Local Authority shall submit the Draft Plan with or without amendment to the Central Town and Country Planning Board.

  1. Submission to the Governor of Sabah (TYT Yang D-Pertua Negeri)

After adoption of the Draft Plan by the Central Board, the plan will then be submitted to the Governor for approval. The Governor may approve the Draft Plan without modification or may refuse approval

  1. Release of notice of approval and publication of approval in the government gazette

Policies and guidelines used

  1. Town and Country Planning Ordinance (Cap 141)
  2. Structure Plan
  3. Report of survey of the respective area

Limitation and gaps of the current process and procedures of land zoning

  1. In the current process of land zoning and application, there is a lack of co-ordination from other departments, and thus an absence of input. Because expertise from these departments, particularly in terms of environment, is not sought, environmental consideration is not adequately addressed in the preparation of the land zone plan.
  2. The lack of co-ordination and participation of other departments in the survey and research stage of planning may also lead to inadequate information about the sites to be zoned for development, which then leads to conflict between departments after approval of project or development plan.
  3. At present there are no environmental guidelines used in the process of zoning and land alienation for development. Although there is an existing environmental framework, this is treated as reference only and not as mandatory guidelines..
  4. Exclusion principles alone are not sufficient for environmental protection and natural resources conservation In land development process, illegal development often occurs prior to land alienation, which often complicates the process of land zoning as well as mitigation of environmental damage. The present criteria use in spatial planning are population, infrastructure and land capability classes. Habitat mapping is not addressed as the first layer of the plan.

4.3.3. Land Alienation

Land Alienation is the responsibility of the Land and Survey Department. The process involved in Land Alienation is summarised in the following:

4.3.4. Land Development

Application of land development usually comes first to the Local Authority who will distribute this application to various departments for comments.

Process within the Department of Town and Regional Planning

The Development Control Division will conduct a survey or site visit to make sure that the development plan fulfils the planning requirement. After the survey a report will be prepared and comments is submitted to the Local Authority

Process outside the Department

Planning application and comments received from various departments will be brought to the Town and Planning and Building Plan Committee of the respective Local Authority for decision.

4.3.5. Policies and Guidelines Used

4.4. Legislation

This section briefly outlined some of the legislation relevant to environmental management in Sabah. This section will not attempt to describe the legislation, as much of the legislation has been explained in detailed in the Institutional Work Group report.

4.5. Environmental Management Tools

Until 1998, the only legal tool used in addressing environmental issues is the Environmental Impact Assessment (EIA) which is a legal requirement under the Environmental Quality Act (EQA) 1974, as amended in 1985. The EQA is a legal framework to manage the environment and the most significant mechanism is the implementation of Environmental Impact Assessment (EIA). In Sabah, EIA is a mandatory requirement under Section 34A of the Environmental Quality Act, 1974 for activities prescribed in the Environmental Quality (Prescribed Activities) (Environmental Impact Assessment) Order 1987. In August 1998, the State Department of Environmental Conservation was formed which will be responsible for enforcing the newly enacted Environmental Conservation Enactment 1996. Under Section 5 of the Conservation of Environment Enactment, 1996, EIA is mandatory for activities prescribed in the Conservation of Environment (Prescribed Activities) Order 1998.

4.5.1. Environmental Impact Assessment (EIA)

The Existing Process and Procedure of EIA in Sabah

EIA is a mandatory requirement under Section 34A of the Environmental Quality Act, 1974 for activities prescribed in the Environmental Quality (Prescribed Activities) (Environmental Impact Assessment) Order 1987. It is also mandatory under Section 5 of the Conservation of Environment Enactment, 1996 for activities prescribed in the Conservation of Environment (Prescribed Activities) Order 1998. Any person intending to carry out any prescribed activity need to submit an EIA report to the Director General of Environment / Director of Environment Conservation for examination.

The present EIA process and procedures organogram is shown in Figure 1 and is summarised in the following successive steps:

  1. Identification of the requirement for an EIA study i.e. to determine if the project fall within the definition of "Prescribed Activity".
  2. Screening of project options with respect to alternative sites and process/design variants with the aim of selecting the optimum site and design concept based on economic, engineering, social and environmental criteria.
  3. Scoping to identify issues of potential environmental concern such that a Term of Reference (TOR) for the EIA can be defined.
  4. EIA Study commences covering detailed identification of potential impacts, baseline surveys and data gathering, prediction and evaluation of impacts including, if appropriate, risk assessment, mitigation and abatement of impacts and Environmental Monitoring and Auditing (EM&A) requirements.
  5. Documentation of the EIA according to content and format requirements of the EIA guidelines.
  6. Review and decision on approval of the EIA by DOE whether to approve with condition or to reject with reason.
  7. Environmental Management Planning which refines the recommendations on mitigation and EM&A in the EIA into an effective environmental protection strategy that demonstrates compliance to the terms of the EIA's approval.

Involvement of other Departments

Many government departments are involved in the process of EIA. The level of involvement however, varies depending on the nature of the development project for which the EIA study is carried out. The involvement of other departments in the process of EIA begins in step (4) and (6) above. In step (4) the project proponent and the EIA consultant will need to liase with the relevant department in conducting of the baseline surveys. At the conclusion of the study, the E1A report is also distributed to the relevant departments and agencies that are invited to sit as review panel to review and assess the study. The level of involvement of other departments in the present EIA process is summarised in the following:

Limitation and Gaps of the Present EIA Process as an Environmental Planning Tool

There are several limitations that can be found in the present EIA implementation in the state of Sabah. One of the most important limitations is the lack of awareness of the strength of EIA as a planning tool. This has led to lack of co-operation from developers. Many perceive the EIA as hindrance to development. This hindrance may be in the form of delay in project approval and implementation or the length of time taken in the EIA study and the delay in review process. Also EIA studies are often carried out late in the planning process after the final plan design is completed and approved which leads to difficulty in changing the design when EIA studies find unsuitability of the plan. As shown in Step (1) of the process, EIA study is only required if the project falls within “prescribed activities” list and there is no legal requirement for those activities that are not subjected to EIA Order. The problem in this process is that the “Prescribed activities “ lists are project and site specific that have not taken into account the cumulative effect of the activities that are outside of the “prescribed activities.” Often EIA studies are omitted when the size of the project does not fall in the “prescribed activities” although the project might be detrimental to the environment.

Also state land forest areas and environmentally sensitive alienated land are not covered in the Forest Management Plans, and EIA is not undertaken for logging activities, even on Forest Land.

The EIA report has also been misused as a step to get approval for the proposed project development rather than for environmental management consideration. This may lead to the mitigation measures and EMP provided in the EIA report being not adhered to or avoided altogether.

Other area of limitation found in the EIA process is the lack of expertise and knowledge by the department personnel required in evaluating EIA reports.

Limitation Identified in the EIA Report

The EIA report has also been misused as a step to get approval for the proposed project development rather than for environmental management, and the mitigation measures and EMP provided in the EIA report may not be adhered to or may be avoided altogether.

The section on Statement of Need is sometimes biased in favour of the project and there is nearly always inadequate discussion of alternatives.

The report is usually a big document and needs sufficient time to review. Tables and matrices are also difficult to absorb, visually and intellectually and there is no way of checking the reliability of information and data analysed in the report. As the time is often too short to complete the study, data collection is not carefully planned.

There also is a lack of transparency in the method, data and information in the report. Because EIA is a guess of future happenings, the report is often weak at predicting impacts.

List of Activities, Which are Not Within the “Prescribed Activities” that Have Been Identified to Cause Significant Impact to The Environment

  1. Marine sand mining (under 50 hectares) within 1.5 km of the coast
  2. Land development for Agriculture (under 50 hectares)
  3. Conversion of mangrove swamps (less than 50 hectares) into agricultural estates and (under 30 hectares) into industrial, commercial or housing estates.
  4. Reclamation of wetlands (any size)
  5. Hill cutting (not exceeding 50,000 m 3) or below 20 o slope
  6. Development of commercial, housing or industrial estates of an area not exceeding 50 ha.
  7. River sand/rock mining (Environmental Conservation Enactment 1996)
  8. Livestock farming (particularly pig farming.)
  9. Oil Palm Mill (Environmental Conservation Enactment 1996)
  10. Hydroelectric power plant
  11. Wood base industries (Environmental Conservation Enactment 1996)
  12. Vehicle workshop
  13. Construction of Permanent Jetties
  14. Agro-base Industries

Figure 1: EIA Procedure (Preliminary)

4.5.2. Environmental Monitoring

The Current Status of Environmental Monitoring in Sabah

Some of the important task in the coastal zone management is to compile baseline information and the understanding of linkages to establish cause and effect of environmental changes. Generally, some of the information needed in dealing with the biophysical and environmental aspects is:

Presently several departments/agencies are involved in environmental data collection such as DID, DOE, JKR, University Malaysia Sabah, Geological Survey Department and Health Department. The parameters that are currently monitored by these departments are:

Standards Used

In Sabah as well as in Malaysia, standard for monitoring of noise, water quality and air quality uses the standard recommended by the Malaysia Department of Environment shown in Appendix 2.

Limitation Identified in the Current Process of Monitoring

  1. The parameters for environmental monitoring need considerable improvement. At present the DOE only monitors two parameters, which are inadequate to determine the overall condition of the state. The main environmental parameters or the criteria for their determination that should be used have not been defined.
  2. Present monitoring is inadequate as it is only done to meet a particular agency’s requirements and does not provide sufficient data to establish an overview of the environment and natural resources situation in the coastal areas as well as for the whole state of Sabah.

Overall environmental monitoring co-ordination between agencies does not exist. Data management of the generated data is inadequate.

  1. Sampling is not sufficient in the number of samples taken (frequency of sampling). The present monitoring systems do not have a standard for methods of sampling and analysis, resulting in unreliable results. Sampling location, and sampling method are not well defined in the present monitoring process. Sampling intensity is often not sufficient to provide accurate results.
  2. A single agency with overall responsibility for environmental monitoring in Sabah does not exist. No methods have been developed for monitoring biodiversity. Baseline data on ecological other natural resource parameters are still lacking.
  3. The present monitoring for pesticides is only for pesticides in vegetables and no monitoring is done on pesticides that get into the water bodies. This lack of adequate monitoring applies also to other ecological toxins.

4.5.3. Environmental Auditing

Environmental audit provides the means by which existing environmental conditions can be defined and compared to provide a ‘snapshot’ of environmental change set against a defined time-frame. Environmental audit can be considered in two forms.

In certain industries or resource exploitation processes, it is possible and increasingly more common; to demand an annual audit of the consumption of energy and raw materials, waste production, and waste treatment by the industry concerned. Such audits may form part of the licensing and monitoring of these processes and serve also to maintain high standards of environmentally sound development.

A more difficult audit is to establish the situation of the natural environment by an audit of natural resources and land use. Such an audit cannot accurately be done until substantial quantitative databases of natural resources are available. However, it is possible in all cases to develop qualitative analysis systems that can show the trend of change in natural systems while at the same time adding to the existing database.

The current mechanisms for environmental auditing are:

Environmental Audit in Sabah

Environmental audit of industrial and resource exploitation processes is not practised in Sabah at present. It may be that future legislation and regulation may allow for this system to be introduced, initially in a limited form to specific hotspot issues or areas. Natural resource audit will be even more difficult to develop because it requires a time-series quantitative database.

Nevertheless, as a long-term objective, the following initial steps may be taken towards developing environmental audit:

Limitation of the Current Process of Environmental Auditing

  1. The current auditing mechanism is inadequate as it is only done specifically to meet a particular agency requirement and is not satisfactory to establish an overview of the environmental quality and natural resources and is not adequate to monitor compliance to policies.
  2. The present mechanism is a reactive basis of auditing where auditing is done only when there is an indication of problems.

4.6. Institutional Framework a nd Capacity

4.6.1. Institutions

Institutions that deal with environmental issues at present are of two levels, the Federal and the State level. At the Federal level, the institutions that deal with the environmental issue particularly monitoring and management of the coastal zone are DOE under the Ministry of Science Technology and the Environment (MOSTE), DID, the Malaysian Institute of Maritime Affairs, the Malaysian Meteorological Service and the Marine Department.

At the State level, the Department of Environment Federal (DOE) is responsible for enforcing the Environmental Quality Act 1974 (EQA). The Department of Environment Conservation under the Ministry of Tourism, Environmental and Science and Technology has recently been formed and provide advice on development of land as well as coastal resources development. The Natural Resources Office and the Lands and Surveys Department (tenure of coastal lands) under the Chief Minster Department, the Department of Drainage and Irrigation (for, rivers, coastal erosion and engineering), the Department of Industrial Development and Research (industrial development planning) the Ministry of Local Government and Housing, Local Authorities (the Municipal councils), and Town and Regional Planning Department (planning at town and district level) are also involved directly in environmental issues. Other departments involved in one way or another are Department of Forestry, Department of Fisheries, Wildlife Department, and Sabah Parks, Ports and Harbour and Agriculture Department. With such a range of departments involved, each individual approach is based on an individual sector basis and there is no integration or co-ordination to the management of land/coastal resources. Departmental jurisdiction often overlaps. There is inadequate co-ordination and co-operation between federal and state departments and NGOs in dealing with environmental issues.

Environmental damage is often caused by development, industry, agriculture and natural resource exploitation without any remedial measures being effected.

4.6.2. Human Resource and Expertise

Lack of Manpower

One of the impending problem in managing the environment in the state is the lack of manpower to carry out the responsibilities entrusted to the department. The Federal Department of Environment in the state for example is extremely under-staffed to handle environmental complaints for the whole state. For example, since the enforcement of the Environmental Quality Act 1974 was extended to Sabah, there has only been one office of the Federal Department of Environment in the State that looks after the environmental issues both for the whole state of Sabah and the Federal Territory of Labuan. There is no branch office that takes care of environmental problem at the district or local level. This has been a major drawback of the department and the State in arresting environmental problem in the state.

Lack of Qualified Personnel

Although environmental consideration into sectoral planning and socio-economic development has been emphasised and outlined in the Third Malaysia Plan 1976-1981, the field of Environment has been slow to attract interest of students from Sabah to pursue training in this field until the late 1980’s, to early 1990. This has resulted in the lack of qualified personnel to handle environmental issues. Many of the personnel involve in evaluating environmental reports do not have Environmental Studies background and this has marred the effectiveness of understanding the real issues and the magnitude of impact of developments to the environment.

4.7. Environmental Issues

A survey of selected environmental issues was carried out from 28 th January 1999 to 1 st April 1999 as a rapid assessment of the four environmental issues identified by the Environmental Work Group. The environmental issues are waste disposal, wetland reclamation, livestock farms and river sand mining. The survey covered 18 coastal districts, namely Papar, Penampang, Kota Kinabalu, Tuaran, Kota Belud, Kudat, Kota Marudu, Pitas, Kuala Penyu, Beaufort, Sipitang, Sandakan, Beluran, Kinabatangan, Lahad Datu, Tawau, Semporna and Kunak. The assessment included discussions with the local authority and representatives of relevant government departments in the districts mentioned earlier, and sites visits to selected areas. A detailed report of the survey is presented in a separate report while a summary of the survey is presented below:

4.7.1. Waste Disposal

Most of the districts have their own by-laws such as Anti-Litter by-laws and Conservancy and Hygiene by-laws to handle waste disposal problems in their respective districts. Other relevant departments such as Department of Environment and Health Department usually handle waste disposal problems outside the local authority’s jurisdiction. At present, there are no regulations in the local authorities on how wastes are to be sorted. The few recycling facilities that are available in the districts are found in Tuaran and Kota Kinabalu .

Each District Council provides waste collection services to the public within its rating area. However, waste collection services in some districts such as Kota Kinabalu, Tawau, Sandakan and Lahad Datu is under the management of private waste management companies. The fee for the service is included in the assessment tax imposed by the Council for residents living within the rating area. In most of the districts, residents living outside the rating area could request for waste collection service from the Council provided that they pay a certain amount of fees determined by the Council. The fee usually depends on the accessibility, distance and frequency of service. Districts with no rating area at present such as Beluran and Kinabatangan usually impose a RM15 fee per month for residential area and RM30 per month for shophouses for waste collection services. The Council usually provides waste facilities such as bins in commercial areas. However, not all district councils provide bins to residential areas and villages within the rating area.

Sewerage and wastewater facilities such as oxidation ponds and treatment plants are only available in 12 districts namely Papar, Penampang, Kota Kinabalu, Tuaran, Kota Belud, Kota Marudu, Beaufort, Sipitang, Sandakan, Lahad Datu, Tawau and Kunak. Those without such facilities have individual septic tanks. All the districts usually organise awareness raising campaigns on environment, for example, “gotong-royong” prior to major celebrations such as Malaysia Day. Towns involved include Papar, Penampang, Kota Kinabalu, Tuaran, Kota Belud, Kudat, Kota Marudu, Pitas, Kuala Penyu, Beaufort, Sandakan, Beluran, Kinabatangan, Lahad Datu, Tawau, Semporna and Kunak.

Information gathered from the discussion with the representatives from the local authority and various government departments (such as DID, PWD, etc) during the survey indicated that the common potentially polluting wastes identified in the 18 districts are industrial wastes (e.g. oil palm plantations), plastics and oil from workshops. Other wastes mentioned were wastes from livestock farms and discharge of raw sewage into sea/river.

All the 18 districts have an official dumping ground on land especially designated for the purpose or rented from villagers. The dumping ground in Kayu Madang, Telipok is the only one that operates based on the sanitary landfill system among the 18 districts. This dumping ground caters for wastes from Kota Kinabalu and Penampang. Tuaran District Council also sends some of the wastes (e.g. residential waste) collected from the district to Kayu Madang. The rest of the districts have open-space dumping ground. For this type of dumping ground, the accumulated wastes are either covered with soil or pushed into a valley, depending on its location. It was observed that the open space dumping grounds provide operation centres for scavengers and breeding ground for rodents and other pests that could be potentially disease carriers.

Limitation in the Area of Waste Disposal in the Surveyed District [10]

Regulations pertaining to waste disposal: Most of the representatives of the local authorities indicated that the by-laws for the districts are outdated Views were also expressed on the difficulty of enforcing the by-laws. The problems of enforcement include limited power of the local authority under the by-laws and the lack of enforcement officers. The lack of awareness on the part of the public and individuals regarding the by-laws and the lack of understanding of the system makes it difficult for the authority to impose penalties on individuals regarding indiscriminate dumping of waste. The lack of awareness and appreciation of the public on the system have often resulted in grievances toward the Councils when required to pay any fines by the district councils.

Indiscriminate waste disposal: Generally, most of the towns and villages visited within the coastal zone face similar problems of indiscriminate waste disposal. As a means to dispose off wastes, residents without waste collection services usually opt for burning, throwing into the river and digging a hole on the ground. Indiscriminate waste disposal is serious in squatter settlements. There is a serious problem of public attitude towards the environment, in these areas.

The problem is also aggravated due to the limited rating areas in each District, resulting in indiscriminate dumping of waste in the district outside the rating areas, in backyards, roadsides, in waterways, etc.

Public awareness/attitude on environment: The attitude of the general public towards the environment contributes to a large extent to the waste disposal problems in every district. Based on the information gathered from the survey, the negative attitude of the people towards clean environment and proper waste disposal has resulted in a major problem of cleanliness in most areas. In most cases, awareness does exist, but the irresponsible attitude prevails more. This is observed in the illegal and legal communities alike.

Waste collection services: There is a lack of efficiency in the waste collection tasks in each District. This is due to the lack of supervision and also lack of commitment to excellence on the part of the workers, and lack of funding on the part of the Authority.

Waste collection services have been restricted by the lack of funding, vehicles and manpower in some districts, for example Penampang, Papar, Pitas, etc. One of the funding problems for the district councils is the late payment or non-payment of assessment tax by some residents. Some districts, for example Tuaran, have a small rating area and hence, collection services are also limited.

The dumping ground system in most districts is a simple open-space system. Wastes are dumped on the ground by the dump trucks and compacted with soil from time to time. However, the absence of security in most dumping ground has opened the doors to scavengers to operate. Scavenging problem in some areas are seen to be serious to a point that houses (squatter houses) are being constructed in dumping ground areas. This problem was observed during the site survey.

The condition of the dumping ground system in most Districts is not well managed and without sanitary landfill system. This is due to lack of funding on the part of the Authority and also non-payment of assessment tax on the part of the public.

4.7.2. Wetland Reclamation

From the information obtained through discussions with the local authority and government departments’ representatives during the survey, there were only a few known wetland development proposals in the 18 districts, namely Papar, Pitas, Kuala Penyu, Beaufort, Sandakan, Beluran and Semporna. Development proposals are mainly for aquaculture projects and housing/shop-houses development, and some for industrial and tourism development projects.

Information obtained from the WWF Sabah Conservation Strategy report regarding wetland area is the list of mangrove forest reserve and two mangrove areas under the virgin jungle reserve classification. This information is presented in Appendix 6: Information on Wetland in Sabah .

4.7.3. Livestock Farms

At present, it is not compulsory for operators of livestock farms in the state to obtain a licence to operate. However, commercial farms usually apply for trading licences from the District Office mainly for loan application purposes.

From general and visual observation of the farms visited by the team, most of the farms are reasonably well maintained in terms of cleanliness. Most of the big farms use disinfectant (e.g. virocid, lysol, ‘Dipal’ alfa-laval) for cleaning. However, the odour from the farms is probably one of the problems faced by the people living in the vicinity.

From the 18 districts surveyed, 27 farms were located [11]. Out of the 27 farms which include pig, poultry, duck and cattle farms, only 10 farm operators/managers were available for interviews. Information gathered from the interviews show that most of the farms dispose off their wastewater directly into a drain. Solid livestock wastes are usually used as compost. Because the wastewater is disposed directly into drains, there is a threat of water pollution from these farms.

4.7.4. River Sand Mining

From the interviews carried out with the local authorities, a ‘Temporary Occupancy Licence’ (TOL) is required when a river sand mining activity is carried out on a state land. However, a permit is still required even though an individual or a company carries out the activity on a private land.

Generally, the procedure to obtain a TOL or a permit is to submit an application to the Land Office. Comments from relevant departments such as the Department of Irrigation and Drainage will be sought by the Land Office. The TOL application will then be submitted to the Director of Lands and Survey Department and the Secretary of Natural Resource Office for approval. An endorsement of the TOL from the Assistant Collector of Land Revenue (ACLR) is required before any operation can commence.

A written clarification was obtained from the Lands and Surveys Department pertaining to the sand mining activities in rivers as described in the following:

Clarification received on 5/5/99 (Wed). Incorporated on 6/5/99 (Thu). No person or company shall extract or remove any articles which include any river sand from any land within the State of Sabah except in accordance with the provisions as provided in the Sabah Land Ordinance. A Temporary Occupation Licence (TOL) is needed in which the sand extraction activities are within the State land. For those with titled land, the landowners are obliged to apply to the Director of Lands and Surveys for permission to do so. The TOL or titled land only convey the surface right of the land to its holder, the extraction or removal of any sand or articles from the land shall need a licence as spelled out under section 23 of the Land Ordinance Cap. 68. The extraction licence shall be issued by the Assistant Collector of Land Revenue in accordance with Land Rule 3 of the Sabah Land Ordinance. On the above basis, for a person or company to operate a quarry or sand mining legally, two approvals from Lands and Survey Department are required:

Due to various environmental issues associated with the sand mining activities in rivers (e.g. erosion, pollution, siltation and etc), the Department is very careful in processing the TOL applications. All applications are referred to the Department of Drainage and Irrigation, the Department of Environment Conservation, and other relevant Departments for their technical comments. If considered and approved, the TOL shall be issued subject to payment of the TOL fee and terms and conditions. The terms and conditions so imposed are usually based on the comments of the technical Departments and those, which may reduce the impact on the environment.

Based on the record of Lands and Survey, the number of land applications so far received for the purpose of sand mining on TOL basis by Lands and Survey Headquarters is less than 460 applications. At the moment, there are only about 80 applications (TOL) still outstanding for processing. This figure is not significant as compared to the total number of land applications, which are still outstanding. The balance (about 380 applications) have either been rejected or approved with or without TOL's.

About 100 of the approved applications have never been issued with TOL's because the applicants failed to take a follow-up action to appoint licensed surveyor to carry out the survey of the lands/areas. As it is, the Assistant Collector of Land Revenue could/does issue licence under Land Rule 3 (2) for the extraction of river sand on titled lands especially those lands affected by rivers without reference to the Director of Lands and Surveys. The Assistant Collector of Revenue of each district should be consulted for information pertaining to the licence.

The Department is of the opinion that the most important reasons for the illegal operation of sand mining in Sabah are not due to the delay in processing TOL applications, but as follows:

Ten river stone/sand-mining companies were identified during the survey of the 18 districts. One sand mining company in Sandakan operates on an ‘artificial or excavated river’ (‘Sungai Korek’). Another sand mining company in Tawau also operates on land in, which involves dredging sand from the ground and not river.

The status on whether the sand mining companies are operating legally or illegally could not be determined during the survey. Only some of them have signboards indicating the company’s name.

As a general observation of the rivers surveyed in the 18 districts, most of them are exposed to the problems of erosion and sedimentation. Erosion problem is faced in Sg. Kedamaian in Kota Belud, Sg. Tuaran in Tuaran, Sg. Lingkungan in Sipitang and Sg. Padas in Beaufort. Sand deposits due to flooding were observed along rivers such as Sg. Kinabatangan, Sg. Tuaran and Sg. Lingkungan. Serious sedimentation problem (i.e. very murky water) was observed in Sg. Kinabatangan, Sg. Padas, Sg. Bandau, Sg. Segama and Sg. Tuaran. Other rivers with moderate sedimentation problem (moderate murky water) include most of the rivers in Beluran, Sg. Lingkungan, Sg. Sibuga and Sg. Segaliud in Sandakan, Sg. Apas and Sg. Tawau in Tawau, and Sg. Kalumpang in Kunak. Pollution in terms of wastes in rivers was only observed in Sg. Petagas near the Kota Kinabalu International Airport. From the information gathered through the discussions with the local authority and government departments’ representatives of the 18 districts, the problems are due to excessive sedimentation resulting from sand excavation and destruction of riverbanks.

4.7.5. Limitation of the Survey

The Environmental Hotspots Survey was conducted as a rapid assessment of the environmental problems in the coastal districts. Ideally, a detailed survey of each of the identified hotspots in the 18 coastal districts covered in the survey would have given a better analysis of the real situation on the ground with regards to environmental problems. However, due to time constraint of the survey as well as the ICZM project, it was not possible to conduct a detail survey in the identified hotspots. Inaccessibility to some of the hotspots areas also made it impossible for survey to be conducted resulting in some areas to have been entirely omitted. Other hotspots area such as sedimentation and erosion of the coastal areas were also omitted due to time constraints. Data presented in the hotspots survey reports therefore, must be interpreted with caution as these data are only based on a single visit and a single visual observation. No detail analysis was conducted on any of the parameters identified.

[5] Classification for Wetlands and Deepwater Habitats, U.S. Fish & Wildlife Service

[6] Detailed of the habitat classification can be obtained from the Sabah Coastal Zone Profile 1998.

[7] Habitat Map can be found in the Sabah coastal Zone Profile and is also appended in this report for reference.

[8] Table x – Review of the GIS data for the Classification of Coastal Habitats

[9] Source: Land Capability Classification in Sabah. A general Inventory of Land Resources. Technical Monograph 1. Technical Sub-committee on Land Capability Classification of the State Development Planning Committee.

[10] Although it is recognised that liquid waste constitute an important environmental issue in coastal districts as confirmed in the discussions with District Officers, only solid waste disposal was addressed in the Rapid Hotspot Survey.

[11] Full report of this is presented in the “Environmental Hotspots Survey” Report.