Article originally published here: https://www.freemalaysiatoday.com/category/opinion/2016/12/14/penang-transport-master-plan-a-scandal-in-the-making/
It has been almost a month since I last wrote a piece Debunking the Penang government’s transport master plan spin highlighting significant concerns on the Penang Transport Master Plan (PTMP) but I have received no response from the Penang state government.
Nevertheless, this latest article will point out serious concerns regarding the modelling methods, ridership forecasts and the decision-making process adopted in the PTMP, subsequently comparing it with best practices adopted in developed countries.
However, this article inevitably raises more questions than it answers, and issues which the Penang state government has to provide clear answers and clarifications.
Questionable PTMP modelling methods and results
Based on the limited information available on public domain, it appears that the “Four Stage Travel Demand Model” is employed by SRS Consortium (PTMP Project Delivery Partner) to estimate long-term ridership forecasts for the overall transport master plan.
While it is understandable that most people will not understand how the model works in detail, in a nutshell, the “Four Stage Travel Demand Model” is an outdated approach first implemented in Detroit and Chicago during the late 1950s.
Although one might argue that this model is still being widely used in transport modelling in the present day, its results are only applicable for short-term forecasts. For example, this model is still used by Transport for London (TfL) today, but only to estimate the severity of network disruptions for accidents and short-term road closures.
In other words, ridership forecast results produced for the PTMP are highly questionable as the “Four Stage Travel Demand Model” is not suitable for long-term ridership projections. Instead, a more accurate approach for long term forecasting 20 to 30 years into the future is to adopt a combination of land use and transport models.
To make matters worse, there are even serious allegations on the population forecasts produced for the PTMP, which the state must provide clarifications. For example, 300,000 people are projected to live in the three proposed “SRS islands” to be reclaimed. The location of these three islands to be reclaimed is shown in yellow on figure 1 below.
Putting it into context, this implies that the population density for these islands has to be around 17,000 people per square km, which is almost equivalent to Hong Kong! For a comparison, the population density of Penang Island today is only around 2600 people per square km (excluding undeveloped areas).
How realistic will it be for 300,000 people to be living in these reclaimed islands in a few decades when it took 200 years for Penang Island’s population to reach the present 800,000 people? Why is the Penang state government not questioning these results?
We often question the intelligence of BN politicians for accepting and rubber-stamping every policy with blindingly obvious flaws. At the moment, is the opposition any different when compared to them?
Based on these allegations, I would strongly urge the Penang state government to fully disclose the PTMP’s modelling methods and feasibility studies in order for it to be thoroughly scrutinised by the public. After all, there will be nothing to hide if these ridership projections are conducted in a proper manner.
Best practices in the developed world
Looking at best practices adopted in the developed world, independent transport modellers are often employed to conduct feasibility studies, transport appraisals and ridership forecasts, where the final report and results produced will subsequently be audited.
The accuracy of these appraisals and ridership forecasts is highly important as it enables city planners to determine the most appropriate public transport system, as well as calculating its financial health and future cash flows needed to maintain these infrastructures. In developed countries, the threat of litigation is possible against traffic forecasters who overestimate transport demand.
Referring back to the PTMP, why is SRS Consortium allowed to carry out their own feasibility studies and traffic ridership forecasts for the Penang state government with a potential conflict of interest arising?
In addition, there will be no excuses on why feasibility studies cannot be uploaded on a public domain as these procedures are often conducted in developed countries. An example of this can be illustrated in London where additional airport runway capacity is required, but only one runway can be built either on Heathrow or Gatwick airport. In order to resolve this tight debate and select the preferred airport, the full feasibility report (download here) conducted by an independent commissioner is uploaded on public domain for scrutiny and transparency purposes in decision-making.
Hence, the Penang state government should also follow the footsteps of increased transparency in developed countries by publishing all PTMP feasibility studies and ridership forecasts, as it always claims to be Competent, Accountable and Transparent.
Why the refusal to work together with NGOs?
Based on observations as a bystander in the past few months, representatives from the Penang state government have been unfairly discrediting the alternative PTMP solutions proposed by NGOs such as Penang Forum without providing any clear quantitative evidence.
These unnecessary spinning and personal attacks by the Penang state government, particularly towards MBPP Councillor Dr Lim Mah Hui is extremely worrying as it shows the top leadership’s lack of interest and incompetence in responding to constructive criticisms.
Although I personally do not fully agree with the alternative PTMP proposed by Penang Forum, there are some positive points which does not justify the entire report to be rejected outright by the Penang state government.
Instead of completely dismissing PTMP critiques, is the Penang state government able to present quantitative evidence or feasibility reports through the use of economic appraisals to show that a series of alternative scenarios have been considered?
According to the UK Government’s Green Book on Appraisal and Evaluation, it is mandatory for an alternative proposal to be considered for every project.
In other words, every solution has to be considered transparently and thoroughly by the state through the use of cost-benefit analysis. The selection criteria and ultimate solution chosen for the PTMP must be justified for the project that gives the highest Benefit-Cost Ratio (BCR). Sadly, this very crucial step in deciding the best PTMP solution has been completely omitted by the Penang state government.
Rather than treating NGOs such as Penang Forum as an enemy of the state, why not utilise their technical knowledge in sustainability and work together for a better Penang? Is it not possible to reach a compromise and incorporate certain positive points from the alternative PTMP to improve the overall plan?
At the end of the day, Penang Forum is not a political party and it is not in the interest of an NGO to disagree on the PTMP for the sake of opposition. Not only that, it will be just a gimmick for the state government to incorporate its critics into the Penang Transport Council, but not provide any convincing answers to address their concerns raised.
Competence, accountability and transparency?
To conclude, the Penang state government has to fully address these new sets of questions raised if it is truly committed in fulfilling its CAT framework of Competence, Accountability and Transparency.
One of the most important role for governments is to spend public funds wisely and efficiently. However, the clear mismanagements highlighted in this article pose a serious breach of trust towards ordinary Penangites, who voted overwhelmingly for the DAP in the hope to see an improved practice of good governance and transparency.
It appears to the public that the high competence, accountability and transparency standards once set by the Penang state government during its first term in office is beginning to deteriorate to unsatisfactory levels.
The abuse of power and corruption by the federal government over the past 50 years is well known. However, this does not allow the opposition to be complacent and settle just to be slightly better than them.
As opposition, once a beacon of hope for a better Malaysia, we should be doing better than these mismanagements and formulate effective policies. This is almost equivalent to choosing between two rotten apples without a viable alternative.
After learning about these scandals and numerous attempts on raising this issue internally but to no prevail, I have tendered my resignation from DAP membership. I am not a “Yes Man” and the PTMP scandal without clear explanations from the Penang state government goes against my principles of joining the DAP in the first place towards building a better Malaysia.