Final Together, Protecting the Enviroment

vi. Guidelines for Noise Labelling and Emission Limits of Outdoor Sources;
vii. Planning Guidelines for Vibration Limits and Control;
viii. Technical Guidance on Scoping Preparation of EIA Report for Development on Hill

and Slope Area;
ix. Guidelines for Environmental Noise Limits and Control (2019);
x. Guidance Document on Implementation of Self-Regulation Initiative in Industrial

Manufacturing Premises (2016);
xi. Panduan Pengurusan Buangan Terjadual Daripada Bengkel/ Woksyop (2015);
xii. Guidelines on The Disposal of Chemical Wastes from Laboratories (2015);
xiii. Manual Panduan Pemeriksaan BMPs Untuk Kawalan Hakisan dan Sedimen (2015);
xiv. A Guidebook on Identification and Classification of Scheduled Wastes (2015);
xv. Contaminated Land Management and Control Guidelines No. 1: Malaysian

Recommended Site Screening Levels for Contaminated Land (2009);
xvi. Contaminated Land Management and Control Guidelines No. 2: Assessing and

Reporting Contaminated Sites (2009);
xvii. Contaminated Land Management and Control Guidelines No. 3: Remediation of

Contaminated Sites (2009); and
xviii. Guidelines on The Handling and Management of Clinical Wastes in Malaysia (2009).

The extent of public participation in the EIA process was gradually enhanced. In 1996, for
all detailed EIAs, the Project Proponent was required to notify the public via notification
in local newspapers. In 2007, the DOE made it compulsory for projects subject to
Detailed EIAs to have a public engagement process. The public display of EIA reports
was also improved. In 2009 the Executive Summary of all EIA reports were displayed
on the DOE’s website. This was improved further in 2012 when the full EIA reports were
displayed on DOE’s website making the entire report accessible to the public. Starting
2020, the Executive Summary (infographic form) together with the EIA reports are
published in the electronic media through online newspaper and social media platform
for Public Display.

As a follow up to the MAMPU’s recommendation, an EIA consultants’ registration
scheme was implemented in 1995, for both individuals and company as a means to
control the quality of EIAs. The registration scheme was enhanced in 2007 with an
induction course for all individual who wished to be registered and the requirement for
Continuous Professional Development. The EIA consultant registration scheme was
further improved in 2021 with the introduction of MYCEP.

In 2013, the DOE commissioned the “EIA Effectiveness Study” which led to a number
of recommendations for improvement. These included strengthening of the public
participation process, improving transparency, code of conduct for consultants and
streamlining of the report processing.

In an effort to improve the quality of EIA report evaluation, the DOE implemented a
quality management system and obtained the MS ISO 9002:1994 in the year 2000 for

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the processing of Detailed EIAs. In 2010, the DOE migrated to the MS ISO 9001:2008
and the quality management system was extended to all DOE offices. At present, the
DOE has migrated further to the MS ISO 9001:2015 which focuses on the process and
review of EIA reports as well as enforcement of EIA projects.
The EIA process under the state legislation in Sabah and Sarawak has also undergone
numerous improvements. Various guidelines and handbooks have been published by the
EPD and NREB respectively in addition to numerous seminar and training programme
to educate stakeholders on the EIA process and requirement.
CHALLENGES
Over the years, the number of EIAs has increased – both in terms of numbers (Figure
2.1) as well as complexity.

Figure 2.1 : Number of EIA reports submitted to the DOE by years
(Source: DOE Annual Report, 2020)

The EIA in Malaysia has faced and continues to face multiple challenges in its
implementation.

The blame game never subsides until today : NGOs want everything to undergo
the process, consultants blame greedy developers unwilling to implement their
recommendations, project proponents protest against the high cost they charge do
not commensurate with work results delivered, DOE worry about the level and quality
of public participation, poor prediction, the thin grey line between federal and state
jurisdiction on project assessment, the list does not stop here

Tan Meng Leng, ex-Director General of Environment, 2012
51

What Tan Meng Leng said in 2012 remains true today. Despite the numerous and extensive
improvements to the EIA process, challenges remain because the environmental issues
and projects have become more complex, public expectation and awareness have
risen, competition for land and resources has heightened and the pressures on time and
budget have not ebbed.

Under the Twelfth Malaysia Plan, DOE has embarked on a few projects and studies to
enhance the process and procedure of the EIA management for the country ranging
from the revision of Order, promulgating a special Regulation, enhancing the process
evaluation and also leveraging the compliances and protection of environment.

Increasing Complexity of Projects and Environmental Issues

Projects and associated environmental issues are becoming increasingly complex.
In the early years of the EIA in Malaysia, the focus was often only on water and air
pollution, and sometimes on forests and wildlife. However, over the years, the scope of
the EIA has grown significantly covering a wide range of topics from emerging pollutants,
biodiversity, carbon emissions, human health risk and social safeguards.

Most of the EIA in the early years were for housing, recreational and industrial projects
and were relatively straightforward. However, in the late 1990s and 2000’s, the size
of the projects became larger and more complex. These include some of the largest
infrastructure projects in the country including the new KL International Airport, the
SMART tunnel, East Coast Rail Link (ECRL), Pahang – Selangor water transfer
project, and the Kelang Valley MRT – where the environmental issues were diverse and
very challenging. Similarly, the types of industrial projects have also changed – new
technologies, new pollutants – both of which bring added complexity to the EIA process.

Wrong Public Perceptions

The various stakeholders in the EIA process have differing perceptions of what the EIA
is, what it should do and how it should be done. Because of these wrong perceptions,
the EIA often suffers from being thought of as the tool to solve all problems.

Any development projects would have a substantial impact not only to the environment,
but also towards the economy and the well-being of society at large. Stakeholders often
think that EIAs should address all aspects of environment, economy and social. The
media often publishes reports about the scope of EIA erroneously. For example, the
EIA has been an effective platform for the public to voice out their objections regarding
potential damaging development projects. Hence this could be the reason why many
people wrongly view DOE as the ultimate approving authority and that EIAs are the sole
intervention tool against unwanted development for the country.

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Other misleading perceptions is that consultants may seemingly have a huge say,
than the authority, in recommending if a project should proceed or otherwise. This is a
common thread whereby many perceive that approved projects by the government are
set to be implemented, and the EIA approval was merely a stamping exercise.

Federal and State Jurisdictions

Malaysia’s federal constitution states that land matters – i.e. the administration
of land and natural resources (such as forest, water and minerals) – are under the
jurisdiction of State governments. The exploitation of these land-based resources is an
important source of much-needed financial revenue for the state governments, which
frequently leads to the unsustainable exploitation of natural resources and hampers
the implementation of country-wide policies for environmental protection. Policies rolled
out by the federal government do not have resource mobilisation plans for effective
implementation nor have provisions to provide funds to states for implementation.

Under such circumstances, the EIA process is continuously burdened with projects that
exploit natural resources (logging, mining, reclamation, etc) that are important for state
governments’ revenue but have significant environmental issues. Thus, reviewing the list
of prescribed activities of the EIA especially the new approach of the EIA management
remains ongoing.

Capacity of Stakeholders

There are inherent limitations in the capacity of all stakeholder groups to effectively
undertake, review and monitor EIAs and post-EIA implementation.

The DOE, for example, now has to deal with increasingly complex issues and ever-
increasing public expectation, while the number of DOE personnel has not increased.
There is also a lack of officers with specialized skills while junior officers are needed
to be trained in preparation of future handing over of the review and monitoring task of
EIA reports. The situation is similar in Sabah and Sarawak where EPD and NREB also
struggle with limited resources.

The situation is the same with EIA consultants. Consultants are also struggling to
cope with increasing public expectations and increasingly complex nature of projects.
For example, inability of the EIA consultant or project proponent to make an effective
presentation to DOE or the review panel is a constant problem. Despite various
guidelines and courses, the problem persists.

The capacities of other stakeholders such as other related government agencies and
NGOs are also limited – rendering their participation in the EIA process not very effective.

53

However, in fulfilling the demand to enhance the officers and consultants knowledge
and technical abilities apart from the understanding of the project proponent to comply
with the approval conditions, DOE through EiMAS has formulated and introduced
competency program for environmental officers and auditors for better understanding
of law and regulations.

Gaps in Policy Framework

One of the main weaknesses of project-level EIAs is that it is ineffective in project
selection. Matters as land use allocations in the planning process, policy decisions on
technological and socio-economic issues relating to various sectors, and the setting of
programmes for progressive developments in large areas, may all be decided before a
project-level EIA is carried out. While there is still much flexibility in design and much
scope for mitigation of impacts, project-level EIA is not very good in selection of the
project in the first place. Analysis of alternatives is unwelcomed at the time of project
preparation; it should become part of sector work leading to project identification.

While there has been focus on project-level EIAs, environmental impacts or issues
at the higher-level policies or plans do not get their due attention. There is simply
insufficient environmental consideration at the policy and programme level in Malaysia
(Figure 2.2). Many of the problems that arise at the EIA stage are due to previous
decisions taken before a project brief is developed and implemented. Such matters
as land use allocations in the planning process, policy decisions on technological and
socio-economic issues relating to various sectors, and the setting of programmes for
progressive developments in large areas, may all be decided before a project-level EIA
is carried out.

In this respect, the key weaknesses of project-level EIA include:

i. At the project assessment stage, the number and range of options is often restricted.
Decision on projects are constrained by decisions made at higher levels, often with
little or no environmental consideration;

ii. Project level EIA is insufficient for the assessment of cumulative impacts; and

iii. The evaluation of environmental impacts which may result from indirect and induced
activities from a major development is difficult at project level.

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Figure 2.2 : Development Planning and Environmental Framework
Over-reliance on EIAs
There is also over-reliance on the EIA process. Though there are many other tools which
are available and can be used for environmental protection and management (Figure
2.3), the EIA appears to be the most used, recognised and demanded to be “the” tool
to solve all environmental problems. This in turn creates a greater burden on the EIA
process and DOE to ensure future developments in the country will not have adverse
impacts to the environment.
EIAs can be more effective when it is applied together with other policy tools and
measures, as opposed to an over-reliance on the EIAprocesses as the sole environmental
management tool. Environmental problems can be better solved by optimal use of
other environmental planning and protection tools such as environmental regulations,
enforcement and monitoring systems, land use planning and others in achieving the
environmental management objectives. Better land use zoning, for example, can avoid
projects from being proposed on sensitive areas. Certain issues such as earthworks can
be better managed at the local authority level.

55

Figure 2.3 : Tools for Environmental Planning and Protection
(Source: ERE Consulting Group)

Inadequate Public Participation

Public participation is fundamental in the EIA process. A well planned and appropriately
implemented public participation programme will contribute to better EIAs and to the
successful design, implementation, operation and management of the projects.

With the introduction of various EIA guidelines for prescribed activities and the EIA
Handbook, as well as the increasing awareness of EIA amongst the public resulted in
the growth of public participation in Malaysia. On the proponents’ and consultants’ side,
perception surveys, conducting of stakeholder dialogues and focus group discussions
and town hall meetings have become increasingly common. Public hearings as part of
the requirements for the Special EIA has created an avenue for the general public as
well as other stakeholders to voice out their opinions and queries. On the EIA review
side, DOE has instituted several requirements such as the need to advertise in the
newspapers, the establishment of the EIA review panels and the display of Schedule
2 EIA reports as well as getting feedback from the public. All these have, to a certain
extent, improved stakeholder participation in the EIA process over the years.

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Nevertheless, weaknesses in the public participation process still exist and these include:

i. The inadequacy of engagement particularly during pre-EIA stage;
ii. The engagement is conducted at a late stage of the project;
iii. Social surveys are not comprehensive or reliable;
iv. The right stakeholders are not engaged;
v. Consultants and/or project proponents are not competent in engaging with the

public; and
vi. Public participation during the EIA is not documented properly.

Insufficient Data

The EIA process in Malaysia also suffers from the lack of robust data. EIAs are often
rushed, regardless of whether they are public sector or private sector projects – leaving
little time for a robust data collection programme. The limited budgets allocated for the
EIA also hamper sufficient data collection. The problem is compounded by the consultant
is always a snapshot of the project site and the data by government agencies are not
easily available for use in the EIA.

Poor Quality of EIA Reports

Over the years, DOE, EPD and NREB have instituted several measures to enhance the
EIA reporting to ensure that EIA reports are comprehensive and address all the critical
issues. Some of these measures include the formulation of various EIA guidelines,
issuance of ad hoc instructions to consultants as well as the conduct of EIA forums and
seminars for consultants and project proponents.

Despite these measures, problems with EIA reporting still continue. Most often, EIA
reports are rejected due to the issues below:

i. Reports not being comprehensive;
ii. Reports being difficult to understand, and the language used is poor;
iii. Crucial information not included in the reports;
iv. Old/ outdated information are used;
v. Reports are padded with irrelevant or peripheral information;
vi. Scope of the analysis being too narrow or incomplete; and
vii. Important issues are superficially addressed while unimportant issues are

elaborated in detail.

On top of that, poor quality of reports could be written by poorly trained or inexperienced
consultants with limited data. Although measures are taken to ensure quality of report
is standard across consultants, problems and grouses will still continue if this is not
resolved.

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SUCCESSES

Despite the multiple challenges in its implementation, the EIA system in Malaysia has
seen its fair share of achievements and success stories. It is fair to say that over the past
35 years, the EIA has made a positive difference in project planning and environmental
management in the country. From improving project transparency to enhancing project
planning and design to better mitigation measures and improved awareness, the EIA in
Malaysia is now a household term across all segments of the society.

Improved Transparency and Project Scrutiny

Projects that are subject to the EIA process are subject to greater scrutiny and are more
transparent. As a result of the requirement to involve the public as well as making the
EIA reports public, the public has substantial information about projects at the planning
stage. This access to information allows the public to better understand the project and
its implication to their lives. The public participation process allows the public to provide
their feedback to the government and the Project Proponent. Through the EIA process,
the public has an avenue to voice their concerns and aspirations. In fact, the EIA is often
the only platform that provides the public with so much information about a particular
project. The special provision of the Appeal Board of the EQA 1974 has given a door for
more transparency in the EIA process and approval.

Improved Project Planning and Design

As a result of the scrutiny during the EIA process, Project Proponents are planning and
designing their projects better. The various project options such as project layout or
alignment or design or construction methods, are now being carefully thought through. In
many projects, this has led to better project designs that avoid significant environmental
and social impacts.

Many Project Proponents and their consultants are proactively engaged with their
stakeholders and seek to improve the planning of their projects. It is not uncommon for
projects to go through an iterative cycle of project design and feedback to arrive at an
optimum design.

Improved Mitigation Measures

The EIA process, over the past 35 years, has led to an improved understanding of
the environmental issues and their impacts. Through more sophisticated prediction
techniques, environmental impacts are now being predicted with greater accuracy. This
in turn has led to improved design of environmental safeguards – mitigation measures
that are practical, robust and cost-effective. The dynamics of environmental technology

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to support the project also prevails in the report that lead for better understanding for the
mitigation and action taken of such project.

Greater Allocation of Resources for Project Implementation

As a result of the EIA process, there is a greater allocation of resources for environmental
protection in project planning and implementation. In tandem with the increasing
complexity of the EIA, the amount of money being spent on them have also increased
significantly. It is now rather common to allocate RM 1 million or more to some of the
larger EIAs.

Project proponents are also allocating a significant amount of resources for the design
and construction of mitigation measures. Good examples include the East Coast Rail
Link project which has allocated large sums of money to construct tunnels and wildlife
crossings that will save significant amount of important natural habitats and allow for
passage of wildlife. The Kelang Valley MRT project has invested significantly in many
environmental safeguards, especially to design and construction of noise barriers.

Improved Awareness

The level of awareness on environmental planning and safeguards has improved
across the country. Many government agencies now undertake initial environmental
assessments long before the project goes to the design stage – thereby avoiding potential
environmental problems at an early stage. Almost all feasibility studies or masterplans
for various infrastructure or townships in Malaysia now include environmental and
social assessments – providing an opportunity for project planners to identify and avoid
potential impacts at the early stage.

WAY FORWARD

The EIA has been used in Malaysia since 1988 and has undergone numerous
improvements to ensure its relevance and effectiveness as a tool for project planning and
decision-making. With the fast-changing economic environment, increasing complexity
of projects and decision-making and the ever-rising stakeholder expectations, it is vital
that the EIA process is continually improved to remain relevant.

Further improvements to the EIA process are needed mainly because:

i. Development projects and the associated environmental issues are becoming
increasingly complex;

ii. There is a need to facilitate investors, investments and economic growth by
improving government’s delivery system and improving time taken to obtaining
permits and approvals;

59

iii. The public expectation of the EIA process (particularly its effectiveness) in terms of
protecting the environment has risen;

iv. Public demand for transparency, access to information and good governance has
risen; and

v. Sustainable development calls for public participation and this is an important
element in the EIA that needs to be strengthened.

Several key aspects of the EIA procedure have been identified to be further improved
and enhanced, as depicted in Figure 2.4 and elaborated in the following sections.

Figure 2.4 : Five Identified Main Scopes for Improvement Initiatives

Strengthening Policy Framework

The conservation of the environment should be mainstreamed into cross-sectoral
plans such as sustainable development, poverty reduction, climate change
adaptation/ mitigation and trade, and in sector-specific plans such as agriculture,
energy, transportation, fisheries, forestry, tourism and infrastructure. Mainstreaming
environmental considerations in the policies, programmes and plans is a very critical
enabler to ensure the effectiveness of the EIA process. While this is/may be outside the
traditional jurisdiction of the DOE/ EPD/ NREB, nevertheless it has still to be addressed.

Mainstreaming at the national/subnational level involves the inclusion of environmental
concerns in policies and processes touching on several sectors and activities with
national and society-wide impact. The most likely entry points for such mainstreaming
include the 5-year Malaysia Plans, Economic Transformation Plan, National Physical
Plan, National Urbanisation policy, etc. State, regional and local plans and programs
are particularly important entry-points for mainstreaming as decisions at this level have
more direct impacts than decisions at the national level because of the proximity of state
government structures to action on the ground.

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The government shall ensure that environmental concerns are adequately and
systematically considered in the formulation of new policies, programmes and plans. This
can be achieved using various tools including the strategic environmental assessment.
Environmental protection shall be mainstreamed into the policies, plans and projects of
key economic sectors. Some of the priority sectors include transportation, energy and
agriculture.

Strengthening Public Participation

In the wake of increasing societal awareness, easy access to information and the quest
for sustainable development, it is pertinent that public participation in the EIA process
is strengthened. Public participation is mutually beneficial for the Project proponent,
government and other stakeholders. For stakeholders, the benefits of engagement
include the opportunity to contribute as people who know the area/field well, have
their issues heard and participate in the decision-making process. For the Project
Proponent, the benefits of stakeholder engagement include improved information flows
by tapping into local knowledge, having the opportunity to ‘road-test’ the project ideas
with stakeholders and the identification of problems early in the project planning stage.
The earlier stakeholders are engaged, the more likely these benefits are to be realised.

Stakeholder engagement during the EIA review process and project implementation is
equally important as it allows the government and the project proponents to hear from
affected parties and use these as inputs to decision-making about the project.

Building Stakeholder Capacity

Building capacity among key stakeholders is vital for the long-term effectiveness of
the EIA process. Without adequate capacity (personnel, skills, tools), the EIA will be
rendered ineffective.

The capacity of the DOE/EPD/NREB needs to be significantly increased to cope with the
anticipated increase in the number of EIA submissions and to enhance the effectiveness
of the EIA. All aspects of the EIA including enforcement, review of EIA reports, audits, etc
shall be strengthened. In particular, training for EIA review officers need to be significantly
increased including the provision of specialised training courses. In particular, training
courses on evaluation of project options and environmental management in selected
sectors (e.g. energy, transport, agriculture) are needed. A scheme shall be developed
to allow government officers to specialise in their chosen subjects or sectors (subject
matter or sector experts) without losing promotional benefits.

The capacity of government EIA review officers, Project Proponents and consultants can
be enhanced by developing tools and support services. An EIA database (supported by a

61

GIS system) had been developed to support the review process and be made accessible
to all EIA review officers under the digitalization of EIA. The database shall contain
information pertaining to all EIA projects including project boundary, project proponent,
key personnel, nature of project, key dates, and approval references, enforcement
visits, and penalties imposed. Project proponents can be required to provide some of
the information in a prescribed format during the submission of EIA, EMP or monitoring
reports. A compendium of best practices and projects shall be published to help project
proponents and consultants design their projects as well as to recognize good projects.

Consultants too need to be beef up their skills and keep up with the advances in
knowledge and technology as issues and projects become more complex and as public
expectations continue to rise.

Cultivating Integrity & Transparency

Integrity of the EIA system, which is important for ensuring that all participants have faith
in the outcomes, can be achieved in part through having an open, transparent system
with clearly defined objectives and processes and realistic opportunities for participation
by all stakeholders. On the other hand, meaningful public participation cannot take place
without transparent processes that provide for real influence. Cultivating integrity is long
and arduous process, not something that can be done overnight. Changing mindsets
and long-ingrained practices will require time and substantial effort.

The EIA review and decision-making process needs to be made more transparent
and participatory to enhance confidence in the EIA process. The process, procedures,
parameters and criteria for the review of EIA reports shall be well-documented and made
known to all stakeholders. Appropriate information (date of submission, date of review
meeting, decisions, dates of approvals/rejections) on new EIAs being reviewed shall be
disseminated to relevant stakeholders.

The conduct and ethics of consultants shall be enhanced. A system for evaluating
EIA submitting firms/ organizations’ performance that encompasses quality of reports
and presentation. Procedures and criteria for delisting/ penalising EIA consultants for
unethical conduct or incompetence need to be established. Environmental consultants,
particularly those making submissions under the ambit of the EQA/ EPE/ NREO, shall
be regulated by an independent board.

The non-government (NGO, academics, industry representatives) members of the
EIA review panel/ committee play a vital role in the review process and it is therefore
important that their conduct is professional. There is a need for clear criteria for choosing
review panel members including a system for evaluating performance and conduct of
review panel members.

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EIA Digitalization

As the improvement of the good governance of sustainable development in the
country, EIA will continue to play a major role of nation development. Under the 12th
Malaysia Plan, DOE is embarking to strengthen the legal requirements relating to EIA
and good governance in EIA process. There are many attempts to enhance the public
engagement particularly the affected stakeholders, consultants, NGOs and the general
people at large. Ever since 2020, the department has elevated to empower the EIA
procedure in Malaysia, especially to cut the bureaucracy and shortened the process
which is not relevant and does not add value to the EIA process. Consequently, effort on
the enforcement of the post-EIA will be strengthened especially putting more advance
approach on the digitalization in the aspect of reporting, assessment and also monitoring.

In line with the DOE’s focus on the digitalization of the department, which forms one
component of its Strategic Plan, several improvements in this regard are in the pipeline
to further facilitate the EIA procedure, including the evaluation process, as shown in
Figure 2.5.

Figure 2.5 : Five Identified Main Scopes for Improvement Initiatives

CONCLUSION

The EIA has been implemented in Malaysia for almost 35 years. Various efforts have
been made by the DOE, EPD and NREB and other stakeholders to improve the
effectiveness of the EIA and associated processes.

Projects subject to EIAs are generally becoming environmentally friendlier. By
creating a platform for environmental issues to be identified and addressed, the EIA
has enabled mitigation measures to be incorporated into the project design. The fact
that EIA require a formal approval and almost always involve professionals to advise
project proponents, the environmental impacts have also been reduced (although not

63

necessarily eliminated). In many cases, because they are spending time and money
on environmental assessments, Project proponent tend to utilise the EIA findings and
incorporate them into the project design.

The EIA has helped government agencies make better decisions about a particular
project. Present day EIAs contain most of the information that is necessary for good
decision-making – this is also as a result of guidelines and guidance documents that the
DOE, EPD and NREB have issued from time to time. Information such as environmentally
sensitive areas, buffer distances, surrounding land use, short and long-term predictions
– all of which are now standard requirement in all EIA – greatly assist the government
agencies to decide whether a project should be approved or modified or rejected.

It is perhaps pertinent at this point to state that the EIA process is one of the main
triggers that have led to the formulation of other environmental policies and plans and
that have led to numerous environment-related actions and initiatives. The EIA process
of the 1980’s and 1990’s led to increased awareness across the country that in turn led
to the introduction of other regulations and policies – all of which in their own ways help
protect the environment.

Much remains to be done. As the government and various other stakeholders have
done over the past 35 years, the EIA process and requirements need to be continually
strengthened. As the society demands greater level of environmental protection and
quality of life; and as environmental problems and projects become more complex, the
EIA will remain a very important tool in the coming years.

REFERENCES

Rio Declaration on Environment and Development, 1992

www.worldbank.org. Accessed on 25 September 2022

Environmental Quality (Prescribed Activities) (Environmental Impact Assessment) Order
1987

Environmental Impact Assessment Guidelines for Petrochemical Industries, 1994

Environmental Impact Assessment Guidelines for Industrial Estates, 1994

Environmental Impact Assessment Guidelines for Resorts and Recreational
Development, 1994

Environmental Impact Assessment Guidelines for Golf Courses, 1994

DOE Annual Report, 2020

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AUTHOR

Dr Bala is the Managing Director for ERE Aurecon Malaysia – a
specialist environmental consultancy that became part of Aurecon
in 2021. Since June 2022, Dr Bala has also taken on the role of
Market Director, Environment & Sustainability – Asia, responsible
for growing the environment & sustainability business across Asia.

In his 35 years of experience, he has delivered projects in a wide
range of sectors from infrastructure, biodiversity, transportation,
energy and water resources. He has planned and managed over 300 consultancy
projects in Malaysia, Brunei, Indonesia, Bangladesh and Myanmar and has served as
advisor to a wide range of government agencies, private sector and non-governmental
organisations across Asia.

Some of his key projects include National Policy on Biodiversity, Malaysia, Central
Forest Spine Masterplan, East Coast Rail Link (Env & Social safeguards) and the KV
MRT Lines 1, 2 & 3 (Env & Social safeguards).

Dr. Norhazni binti Mat Sari is the Deputy Director General
(Development) of Department of Environment (DOE). She completed
her Bachelor of Science at Universiti Kebangsaan Malaysia, MEng
in Civil Environmental at Universiti Teknologi Malaysia and PhD at
Universiti Kebangsaan Malaysia in Environmental Management
(Environmental Forensics). She has 30 years’ experience in
environmental legislation, environmental forensic and hazardous
waste management. She has been credited with contributions to
scheduled waste management policy and has been appointed as DOE representative
numerous times for national and international conferences, workshops and programs
related to environmental topic. She is also actively involved in the scientific writing and
guidelines publication related to the environmental management for the Department.
She is the first trainer and the module writer for the Scheduled Waste Management
Competency Program of DOE officers and industrial premises. Dr. Norhazni also lead
a committee for enhancement of EIA procedures of DOE and revision of EQA 1974.
She also served in the state environmental management committee in managing the
environmental issue while she was the State Director for Negeri Sembilan DOE office.

65

Until man duplicates a blade of grass,
nature can laugh at his so-called
scientific knowledge.

- Thomas Edison

Melaka, Malaysia.

Chapter 3

Environmental
Quality Monitoring

& Assessment

ENVIRONMENTAL QUALITY MONITORING & ASSESSMENT

Abdul Rani Abdullah & Mohd Faizul Hilmi Zulkifli

INTRODUCTION

Environmental monitoring is defined as the systematic sampling of air, water, soil and
biota in order to observe, record and derive knowledge and information about the
environmental matrix of interest. The data and information generated from monitoring
activities serves to provide a greater understanding of the environment and hence
contribute to the protection of human health and the sustenance of natural ecosystems,
as well as the many beneficial uses and natural resources that are derived from the
natural environment.

Hence, environmental monitoring is an essential element in the management of the
environment. Quality-assured data from monitoring activities allow for the more
sustainable planning of development projects, support the effectiveness of enforcement
activities and ultimately, enhance the overall management of the nation’s living
environment and natural resources. Environmental data that contributes to establishing
the status of the environment also represents a useful tool in assessing the effectiveness
and improvement of management strategies.

On the outset, the distinction between source monitoring and ambient monitoring needs
to be emphasized. Source monitoring refers to the monitoring of emission and effluent
from specific premises/activities that may be subjected to specific regulations. In the case
of Malaysia, the Environmental Quality Act 1974 (EQA ’74) and related regulations may
apply. Hence, for premises for which the EQA ’74 applies, source monitoring is aimed
at ensuring compliance to the stipulated threshold values of specific parameters related
to the characteristics of the emissions and effluents after undergoing the appropriate
treatment process. It should be noted that many point sources are not subjected to
the EQA ’74 and its regulations. Such activities, however, may be subjected to other
legislative control such as the Local Government Act 1976, Street Drainage & Building
Act 1974, the Town & Country Planning Act 1976, as well as related enactments.
These legislations do not generally specify numerical threshold values for emissions or
effluents, unlike the related regulations under the EQA ’74. Appendix 1 provides a list of
regulations under the EQA ‘74 that dictates the parameters and corresponding threshold
values related to emission and effluent characteristics. Another example of legislations
and regulations that dictate threshold values include the LUAS Enactment, 1999.

Ambient monitoring, on the other hand, is directed towards the general environment
with no specific reference to individual sources of pollution. Ambient monitoring may be
contributed by pollution sources but at the same time, is undertaken at a site where the

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general environmental quality is represented. Hence, ambient data may allow for some
indication of pollution sources. As a rule, the sampling point of an ambient monitoring
program is characterized by a well-mixed matrix.

In Malaysia, the systematic ambient monitoring of the nation’s air quality and water
resources, including the riverine systems and groundwater, as well as marine waters
has essentially been the responsibility of the Department of Environment (DOE) under
the Ministry of Environment and Water, although several other government and non-
governmental agencies also undertake some form of environmental monitoring as it
pertains to its respective roles and responsibilities.

This chapter deals with the aspect of ambient environmental quality monitoring as it
pertains to managing the environment in Malaysia, in particular with respect to air quality,
river and groundwater quality as well as marine waters. The chapter commences with
the fundamental aspects of designing a monitoring network, assessment techniques
and related formulation of standards and indices, then focusing on environmental
monitoring activities in Malaysia and finally looking ahead to the future of environmental
monitoring activities and its continued maturation towards a data-driven environmental
quality management system.

ENVIRONMENTAL QUALITY MONITORING NETWORK DESIGN

A Environmental Quality Monitoring Network Design (EQMN) encompasses all the
elements of an environmental quality monitoring program as depicted in Figure 3.1.

Integration Monitoring Parameter
with other Objectives
Number &
factors Env location of
Monitoring sampling
Data analysis Network
& Reporting station
Design

Sampling
Frequency/

Timing

Figure 3.1: Key Elements of an EQMN Design

69

The single most important factor in designing an EQMN is the objective. Monitoring
activities may be undertaken for a variety of purposes, including to establish
environmental baselines and to determined trends, both temporal and spatial as well
as relative to other factors, to assess the effects of anthropogenic activities, as a
basis to formulate policies and management strategies and to assess compliance to
environmental regulations. Environmental monitoring data is also a basic requirement
in the application of environmental quality modelling tools, that provides simulation and
predictive capability and hence has an important role in Environmental Decision Support
Systems (EDSS).

Environmental monitoring programs may also vary in spatial and/or temporal scale,
as well as in scope. An environmental quality baseline study conducted as part of
an Environmental Impact Assessment (EIA) is limited to a localized area, covering
both the developmental and operational phases of the project concerned. A national
environmental monitoring program necessarily encompasses a network representative
of the whole nation and is long-term in nature, while global monitoring programs involves
the collaboration of many countries and again, is generally long-term, as exemplified
by the monitoring of climate change and other programs operated by the World
Meteorological Organization, the Global Atmosphere Watch and the World Conservation
Monitoring Center. In addition, the Global Environmental Monitoring Systems (GEMS)
is responsible for monitoring and reporting on the global state of water, air, climate,
atmosphere and food contamination. These global-scale programs allow for the
collection and dissemination of data and is designed to address global scale issues
such as water security and climate change.

Environmental monitoring activities may be conducted by international organizations,
government agencies, Non-Governmental Organizations, the private sector, including
consulting firms, academia and research institutes, as well as communities.

Effective EQMN design involves not only rigorous application of scientific methods, but
also economic, technical and legal considerations. The key elements in the design of
a effective environmental monitoring programs are described in numerous references.
Lovett et al’s (2007) “Seven habits of highly effective monitoring programs”, are listed
below:

i. Designing the EQMN with clear and compelling scientific questions to be answered;
ii. Including review, feedback and adaption in the design;
iii. Selecting parameters to be measured not only in relation to the present. but also

with the future in mind;
iv. Maintaining the quality and consistency of the data by the application of rigorous

QAQC measures encompassing the design network, sampling & analysis works,
data management, data analysis and reporting;
v. Planning for long term data accessibility and archiving;
vi. Continually examine, interpret and present the data.

The following sections address the key design elements that are related specifically to
air and surface and groundwater quality monitoring network.

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Key Elements of an Ambient Air Quality Monitoring Network Design

The main objective of establishing an ambient air quality monitoring network is the
protection of human health. While such networks may be established to address
localized and specific air quality issues, ambient air quality monitoring networks are
generally established on a national, regional or international scale.

Based on international best practice in ambient air quality monitoring design, the main
design criteria are identified as follows:

i. Selection of parameter;
ii. Site selection and number of monitoring stations (population coverage, spatial

extent, local topography);
iii. Screening criteria; and
iv. Network review process.

The network is designed to meet the objectives of the monitoring program which may
include providing data for environmental management, reporting compliance to ambient
air quality standards, providing information to communities, correlating with emission
control programs as well as providing data for research on human health impacts.

Guidance documents that are commonly referred to in designing a ambient air quality
monitoring network include those from the World Health Organization (WHO, 2000),
United States (US EPA, 1998; USEPA 2005a; USEPA 2005b), the European Union (EU,
2016) and Canada (CCME, 2011; CCME2012a; CCME2012b).

Selection of Parameter

The key air quality parameters monitored in an ambient air quality monitoring

network are Ppabrtaicnudlatmeemteaottreorlo(gPiMca1l0, pPaMra2m.5),eOte3r,sS. OO2t,hCerOpaanrdamnietrtoegrsenmoaxyideaslso(NbOe/
NO2, NOx),
monitored in relation to specific sources of air pollutants such as volatile organic

chemicals (VOC).

The continuous mode of measurement is generally applied in ambient air quality
monitoring programs, while supplementary data from manual sampling using high
volume samplers related to the levels of pollutants in particulate matter may also
be generated in such programs.

Site Selection

Consistent with the primary aim of protecting human health, the selection of sites
in the context of ambient monitoring is generally governed by the objective of the
monitoring station within the network, representativeness and the absence of
obstruction, either natural or man-made structures. The specific objective(s) of the
stations within a network may be categorized as population oriented, source impact

71

(vehicular, industry), regional transport (including transboundary transport) and
background. Typical representative scales include for siting purposes and station
types are provided in Table 3.1 (USEPA, 2005b) and Table 3.2 (EU, 2005b).

Table 3.1: Siting Scales (USEPA)

MICRO MIDDLE NEIGHBOURHOOD URBAN / RURAL REGIONAL
<100m 100m – 0.5km 10/100s of km
0.5 – 4km 4 – 50km

Table 3.2: Siting Scales for the Designation of Station Types (EU)

URBAN SUBURBAN RURAL RURAL / BACKGROUND

A few km2 Tens of km2 100’s of km2 1000 – 10,000km2

Representativeness with regards to human population also plays an essential role
in indicating the number of monitoring stations within a network. The US EPA for
example dictates that the population threshold vary in accordance to the pollutant.
H> e5n0c0e,0, 0P0Mp2.e5ompolen.itCorBinSgAisisredqeufinireedd for every Core Based Statistical Area (CBSA) of
as consisting of 1 or more counties with a urban
center of at least 10,000 people plus adjacent counties that are socio-economically
linked to be urban center. In addition, at least 1abPoMve2.5 monitor is required per CBSA
of > 50,000 people if the concentrations are 85% of the National Ambient
Air Quality S35ta0n,0d0a0rdpse. oFpolreO. 3, on the other hand, 1 O3 monitor is required for every
CBSA of >

As a comparison, the Ambient Air Quality and Cleaner Air for Europe Directive
adopted by the European Union essentially defines a minimum requirement for 1
monitoring station per 250,000 people while in Canada the minimum requirement
is generally 1 monitoring station for a population of 100,000 people.

Screening Criteria

Parameter-specific screening criteria are established in order to optimize the
ambient monitoring network. Hence, preliminary or estimated air quality data (from
air quality modelling exercise) is assessed in relation to the ambient air quality
thresholds, the results of which is used as input into the network design.

THAhmeenbciUeen,SlteEAvPeiArlsQibnuedaliocliawtytethSsetasanedPtahMrrde2.ss5htwhorlhdeislsehreothqldeuiroOef3f8et5wh%reersmohfoolntdhiteoisrcin8og0rr%setsaoptifoonnthdsei.nCgsotanNnvadetariosrdnesaly.l
higher levels may require higher number of stations.

Review Process

Inherent in any environmental monitoring programs, a review process is a
requirement that reevaluates all aspects of the monitoring network, including the
continued relevance of applying the screening criteria as described above.

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The review process is generally scheduled at fixed intervals for a national scale
program and is based on the data generated and changes in land use as well as
development plans and new findings in atmospheric science, monitoring technology
and related aspects.

Key Elements of an Ambient Surface Water Quality Monitoring Network Design

Surface water is defined as any body of water above ground and hence may include
rivers and streams, lakes, reservoirs as well as marine waters. While there may be
specific design elements that relate to the different water body types, many design
elements of a ambient surface water quality monitoring network are applicable to all
bodies of water.

As emphasized above, the major factor in the design of any environmental quality
monitoring program is a clear set of objectives. A common objective includes the provision
of data in the assessment of the suitability of the waters in relation to various beneficial
uses and/or ecosystem health. In addition, monitoring data is also used not only as
a basis of formulating water quality management strategies and plans of action but
also in assessing the effectiveness of such plans. Water quality monitoring data is also
applied in water quality models which is a useful tool in simulating and predicting water
quality and is as an essential element of development planning as well as representing
a component of a decision support system.

Depending on the objectives, the ambient network may range from specific rivers to
an entire river basin encompassing major tributaries at their confluence, including river
segments representing major discharges from urban and industrial areas through to the
tidal limit.

In lakes and reservoirs, the network may be represented by sampling stations located
at transects established to represent the water body. In addition, inlets and outlets may
also be included in the network. The design of monitoring networks to be established in
estuarine waters, on the other hand would need to take into consideration the natural
spatial and temporal variations related to the dynamic nature of such waters. Similarly,
monitoring activities in coastal waters also need to take into account natural tidal
variations, and in populated areas coastal structures that may influence the water quality
measured.

Numerous guidance documents that are commonly referred to in designing an ambient
water quality monitoring network include ISO 5667,1980; UNEP/WHO/UNESCO/
WMO,1981; Bartram, 1996; ANZECC, 2000; USEPA, 2003 and Jiping, Jiang, 2020, to
name but a few.

The main design considerations related to an ambient surface water quality monitoring
network are as follows:

i. Establish the water quality objective(s);
ii. Select parameters;

73

iii. Water quality variability;
iv. Establish number and location of sampling sites; and
v. Establish time and frequency of sampling.

Water quality monitoring networks may comprise sampling activities at designated
sampling sites and subsequent analysis at a laboratory. In situ measurements of
selected parameter may also be recorded in-conjunction with the sampling works. In
addition, the network may also include automatic water quality monitoring systems
that can generate near real-time water quality data.

Automatic water quality monitoring systems generate vast amounts of data and
is particularly useful in waters of highly variable quality. The monitoring capability
allows for such systems to function as early warning system in protecting sensitive
receptors such as water intake points, aquaculture activities as well as the
protection of sensitive aquatic ecosystems. Disadvantages of such systems include
a limited number of parameters, as well as the relatively high cost of procurement
and operational costs.

It should also be noted that while the emphasis of ambient water quality monitoring
programs is focused on the water column, such programs may also include sediment
and biota. The latter two matrices are particularly relevant in the context of certain
types of pollutants (such as heavy metals and persistent organic pollutants), that
have the propensity to associate closely with sediment particles and/or subjected
to bioaccumulation process in the aquatic food chain. The latter represents a health
risk aspect to the monitoring activities.

Water Quality Objective

In tandem with the objectives of establishing the ambient water quality monitoring
program, a water quality objective is also required to be determined.

The water quality objective defines the quality of water that is needed to protect
and maintain the designated beneficial use(s) and environmental values that
is designated of the water body of interest for which the monitoring program is
designed.

The water quality objective is aimed at protecting the most sensitive of the beneficial
uses designated for a water body, defined by corresponding numerical values or
narrative descriptions related to relevant water quality parameters and based on
sound scientific water quality criteria.

In Malaysia, the water quality standards that may be referred to in defining the water
quality objective of surface water are as follows:

i. National Water Quality Standards;
ii. National Lake Water Quality Criteria and Standards;

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iii. National Guidelines for Raw Drinking Water Quality;
iv. National Standards for Natural Recreational Waters and Guidelines for

Monitoring Recreational Waters (Fresh and Marine Waters); and
v. Malaysia Marine Water Quality Standards.

As an example, the National Water Quality Standards, applied to river water quality
are formulated based on specific beneficial uses as well as in relation to the level of
protection of the aquatic ecosystem and categorized as Class I to Class V (Table 3.3).

Table 3.3: Water Quality Classificationas Applied in Malaysia

CLASS DESIGNATED USE

I Conservation of natural environment

Water supply I – Practically no treatment necessary (except by
disinfection or boiling only)

Fishery I – Very sensitive species
IIA Water supply II – Conventional treatment required

Fishery II – Sensitive species

IIB Recreational use with body contact
III Water supply III – Extensive treatment required

Fishery III – Common, of economic value and tolerant species

Livestock drinking
IV Irrigation
V None of the above

Hence, a typical river water quality objective may be defined as “River water shall
not contain concentrations or amounts of physicochemical constituents in levels that
adversely affect Class II use, as defined in the National Water Quality Standards”

Water Quality Parameters

Ambient water quality monitoring programs generally includes a set of baseline
water quality indicators encompassing physico-chemical, microbiological and
biological/ecological parameters. Hydrological parameters may also be included as
in the case of river systems, for example. The parameters chosen should reflect
the defined water quality objective, as well as the overall objectives of the program.
Hence, in recognizing the water quality objective of a river in Malaysia as Class
II, the key parameters defined in the National Water Quality Standards should be
included in the corresponding monitoring program.

75

The tiered approach to monitoring is also recommended, comprising a core set
of indicators as described above that are routinely determined, in addition to
supplemental parameters that are site-specific in relation to potential sources of
pollution as exemplified by the inclusion of pesticides in waters near agricultural
areas. Supplemental parameters are often useful in identifying causes and sources
of impaired water quality and targeting suspected pollution sources.

Examples of recommended water quality indicators in relation to beneficial uses
are provided in USEPA, 2003 (that also includes supplemental parameters) while
Chapman (1996) provides a recommendation of parameters not only related to
various beneficial uses but also those that are associated with industrial sources (eg
petroleum & refining, pulp & paper, metal finishing etc) and non-industrial sources
(eg sewage & municipal, urban runoff, agricultural activities etc).

In designing monitoring networks associated with lakes, reservoirs and coastal
waters, in particular, parameters related to the possibility of the emergence of
algal bloom should also be included. Hence, in situ measurements of transparency
(using a secchi disk), as well as determinations of chlorophyl-a, nutrients, as well
as other related parameters should also be considered. Similarly, coastal waters
exposed to potential oil pollution should be monitored for hydrocarbons, in the form
of total hydrocarbons and fractionations of hydrocarbon species instead of the more
generic oil & grease.

Water Quality Variability

In designing an ambient water quality monitoring program, a good understanding of
the variability of the parameters of interest is essential.

Hence, data generated from any particular sampling site may range from relatively
stable water quality characteristics, subjected only to natural seasonal, tidal
or diurnal variations to wide and rapid variations attributed to scheduled and
unscheduled discharges from a variety of point and non-point pollution sources.

Water quality variability is a function of the parameter in question and is generally
contributed by i) Natural/seasonal factors, ii) Hydrological characteristics, iii)
Pollutant discharge regimes and iv) Hydraulic structure.

A good understanding of contributing factors to water quality contribute to the design
of the monitoring network in terms of site location and timing of sampling for example
and is an essential element in interpreting and reporting the data generated.

Number and Location of Sampling Site

The three general approach to the determination of the number and location of sampling
sites are i) Probabilistic site selection (Simple random, stratified or nested designs),
ii) Targeted & judgemental design based on land-use, geographical & catchment
delineation and natural and human influences) and iii) Integrated tiered approach.

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Whichever approach is adopted, the key criteria is that the number and location of
the sampling sites in the water quality monitoring network will be able to generate
data that meets the objective(s) of the monitoring program.

The distribution of monitoring stations should also take into account processes
and causes/sources that affect water quality. Hence, information with regards to
a source inventory as well factors that may influence data variability need to be
considered in siting considerations.

Spatial representativeness is another essential factor in determining the number
of stations as well as in siting considerations, in particular when extrapolating the
reporting of water quality data derived from individual sampling sites. Ambient
monitoring should also be undertaken at sampling site that represent well mixed
waters, both good lateral and vertical mix particularly with regards to rivers and
streams. The estimated distance for complete mixing from a tributary or discharge
points are indicated in Table 3.4 (Batram & Ballance, 1996).

With regards to lakes and reservoirs, lateral mixing of the water column is generally
low, with limited flow associated with these water bodies particular in large lakes.
Monitoring networks established at lakes, reservoirs and marine waters may
also include the determination of depth profiles related to selected water quality
parameters such as DO, temperature and pH to account for stratification.

Table 3.4: Estimated Distance for Complete Mixing for River & Streams (Batram & Ballance, 1996)

AVERAGE DEPTH MEAN DEPTH APPROXIMATE DISTANCE REPRESENTING
(M) (M) COMPLETE MIXING
(KM)

51 0.08 – 0.7
2 0.05 – 0.3
3 0.03 – 0.2

10 1 0.3 – 2.7
2 0.2 – 1.4
3 0.1 – 0.9
4 0.08 – 0.7
5 0.07 – 0.5

20 1 1.3 – 11.0
3 0.4 – 4.0
5 0.3 – 2.0
7 0.2 – 1.5

50 1 8.0 – 70.0
3 3.0 – 20.0
5 2.0 – 14.0
10 0.8 – 7.0
20 0.4 – 3.0

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In selecting locations of marine sampling sites, representativeness that allow impact
assessment from source to large expanse of mixed homogenous waters is indicated
by the presence of a gradient from source towards the sensitive receptor (s) of interest.

Sampling activities in ambient water quality monitoring networks are generally
conducted at uniform depth (30cm below surface for well mixed waters). Depth
profiles may also be undertaken for selected parameters in deep waters.

Time and Frequency of Sampling

With regards to the timing and frequency of sampling, samples may be taken at
constant intervals within a period of a defined cycle, encompassing both high
flow and low flow for example or in the form of random sampling, spread evenly
throughout the year. An event and/or flow driven regime may also be applied.
Hence, an increase rate of sampling is carried out during low flow and/or in relation
to effluent discharge and runoff.

Sampling frequency may also be guided by the category of the sampling site and
the water body type (Table 3.5) (Batram & Balance, 1996).

Table 3.5: Recommended Sampling Frequency (Adapted from Batram & Balance, 1996)

NO OBJECTIVE RECOMMENDED YEARLY SAMPLING FREQUENCY

RIVER / STREAM LAKE / RESERVOIR

1 Baseline Minimum 4 encompassing Minimum 1 at turnover (Sampling at lake
high and low flow regimes outlet)

2 Trend Optimum: 24, Weekly for Optimum: 1 at turnover and 1 vertical
TSS profile at end of stratification period
Eutrophication issue: 12
Minimum 12 for large
catchment (~100,000 km2) Other issues:

Maximum 24 for small Minimum: 1, at turnover
catchment (~10,000 km2)
Maximum: 2, one at turnover and one at
maximum thermal stratification.

Key Elements of a Groundwater Quality Monitoring Network Design

The beneficial uses of groundwater include domestic use, livestock and irrigation as
well as for industrial use. Monitoring activities related to groundwater quality is generally
associated with assessing the extent of groundwater pollution and the associated
implications to beneficial uses. A groundwater quality monitoring program is also
important in relation to the aspect of aquifer restoration.

In designing a monitoring network for assessing groundwater quality, there are two
important differences that needs to be considered between groundwater and surface

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water; the slow movement of groundwater with relatively large residence times and
the high degree of influence between the groundwater and the material that make up
the aquifer in terms of physicochemical characteristics. Therefore, in considering a
groundwater quality monitoring network, a clear understanding of hydrogeology of the
area of interest is vital, encompassing i) Geological setting (lithology and stratigraphy),
ii) Groundwater flow patterns and volume, iii) Recharge areas and rates, iv) Aquifer
characteristics (such as hydraulic conductivity and dispersion coefficient and v)
Geomorphoclimatic characteristics.

In general, an ambient groundwater quality monitoring network should encompass the
main aquifers of the area of interest, particularly when such aquifers have been identified
as a groundwater resource in relation to some potential or existing beneficial use(s).

The main design considerations related to an ambient groundwater quality monitoring
network are as follows:

i. Density of observation wells;
ii. Selection of parameters; and
iii. Sampling frequency.

Density of Observation Wells

The density and general distribution of the observation wells within the monitoring
network are determined by the following factors:

i. The objective(s) of the monitoring works;
ii. The size of the area that the network serves;
iii. The geological and hydrogeological complexities; and
iv. Land use and potential pollution sources.

The EU guidelines (2016) recommend a geometric pattern of distribution with a
density of 1 site per 20 to 25 km2 of aquifer, identified of significant importance
with respect to beneficial use. It is also recommended that areas with high rates of
infiltration should be monitored more intensively, both in density terms as well as
frequency. Establishing reference observation wells not affected by anthropogenic
activities should also be considered as part of the monitoring network.

Selection of Parameters

Groundwater quality is contributed by both natural as well as anthropogenic sources.
In general, the choice of parameters relates to the objectives of the network.
Chapman (1996) provides categories of human activities and natura process that
may potentially influence groundwater quality and identifies the main parameters
in each category, ranging from urban (including landfill and sewage), industrial and
agriculture to saline intrusion.

79

In relation to assessing suitability of the groundwater for specific beneficial uses, the
corresponding water quality standards and guidelines are referred to. In Malaysia,
the applicable standards are the National Groundwater Quality Standards.

In assessing the effects of pollution, parameters related to the source and types
of pollution should then be included in the monitoring network. Chapman (1996)
provides a recommendation of parameters associated with industrial sources (eg
petroleum & refining, pulp & paper, metal finishing etc) and non-industrial sources
(eg sewage & municipal, urban runoff, agricultural activities etc).

In addition to physicochemical parameters, hydrogeological parameters such as
water level, pump discharge and rainfall/evaporation rate should also be included
in the network.

Sampling Frequency

Because of the generally long residence times and relatively slow rate of change in
groundwater quality less frequent sampling is required compared to surface water.
The frequency of ambient groundwater monitoring wells sampling is generally
recommended as twice a year (EU, 2016) while in accordance to Batram & Balance
(1996), the recommendation is once a year for large stable aquifer and a maximum
of 4 times per year for small alluvial aquifer or karstic aquifer.

The EU guidelines also indicates the appropriate time for sampling, particularly
for groundwater levels relatively close to the surface, sampling should be done
once during a period of high ground water level, corresponding to high infiltration
and recharge and the second sampling to be carried at low ground water level
(corresponding to minimum infiltration or maximum abstraction).

More frequent sampling is required when the likelihood of pollution is high, related
to the type of pollution and the hydrogeological conditions. Hence, more frequent
sampling Is required in cases where pollution sources are associated with a potable
water supply in a highly vulnerable aquifer with rapid fissure flow.

Quality Assurance and Quality Control

To ensure the consistent generation of good data, quality management is an essential
element in designing an environmental quality monitoring program. Quality assurance
and quality control (QAQC) are two aspects of quality management.

Quality assurance encompass all planned and systematic activities implemented within
the quality management system that can be demonstrated to provide confidence that
a product or service will fulfill the requirements of quality, while quality control, being a
subset of quality assurance is the inspection aspect of quality management (https://asq.org).

Hence, in monitoring network design, establishing a comprehensive set of quality
assurance and quality control (QAQC) protocols is a prerequisite element before

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implementation. In fact, the QAQC measures should encompass the designing process
itself, as well as sampling activities, in situ measurements, operation of automatic
monitoring systems, laboratory analysis, right through to data management, data
analysis and reporting.

Quality management systems such as ISO9000 are often applied as a framework to
ensure the consistent generation of good environmental data. Of particular relevance is
the USEPA’s Quality Assurance Project Plan (USEPA, 2002).

Establishing and implementing Standard Operating Procedures (SOPs) is integral to
a quality management system. The SOPs should be based on international-practiced
procedures incorporated with all relevant records to ensure traceability, from calibration
and maintenance records right through to chain of custody. SOPs should also be reviewed
from time to time to take into consideration improved techniques and procedures, as
well as the changes in the scoping of the SOP. In addition to quality assurance elements
for which records should be maintained, quality control elements, encompassing both
field and laboratory controls should also be reported.

Data Analysis and Reporting

Data analysis is to be conducted only on “good data”, data that has passed the QAQC
protocols established for the monitoring program.

Irrespective of the overall objectives of the monitoring program, the most basic form of
reporting of environmental data relates to an assessment of human health impact and
compliance to beneficial use (s) and ecosystem health as it pertains to the corresponding
matrix. Hence, compliance to relevant guidelines and standards is a typical reporting
feature. In addition, spatial and temporal trends as well as correlation between indicative
cause/source and environmental quality are often included in environmental reporting.
An identification of areas of concern (“hotspots”) is also included to bring a focus on
management priority.

In converting data to information, the primary aim of environmental data analysis is
to contribute to effective environmental management. In this regard, environmental
quality parameters alone is not enough. In addition to complementary parameters such
as hydrological measurements related to the aquatic environment and meteorological
parameters with regards to air, interpretation of the ambient environmental quality
database also requires a comprehensive and up-dated set of relevant information and
data that includes at minimum, spatially defined pollution source inventory/land use and
corresponding sensitive receptors. An assessment of an over lay of the latter data with
the environmental network and related database may allow for the establishment of
indications of cause/source and effect relationship, which in turn may provide useful
management inferences. When linked to an appropriate environmental quality model,
all of these features represent key ingredients to an Environmental Decision Support
System (EDSS).

81

The long-term nature of an ambient environmental quality monitoring program result
in a large database and hence lent itself to meaningful statistical analysis, the most
basic of which allow for the determination statistical parameters such as median, mean
(arithmetic/geometric), maximum, minimum as well as percentiles. These statistical
parameters are commonly presented in a box plot. Figure 3.2 shows an example of
such a boxplot, based on an annual WQI database generated from an automated water
quality monitoring network.

Figure 3.2: Boxplot Related to WQI Generated from an Automated Water Quality Monitoring Network

Data generated from long term environmental monitoring network allows for the
determination of environmental status encompassing both spatial and temporal trends,
the identification of “hotspots” and hence, areas of priorities and when assessed in-
conjunction with pollution source inventory, provides cause-effect relationships to be
established. However, it is generally challenging to attribute ambient environmental
quality data with specific sources unless the parameter concerned is source-specific.
Typical statistical parameters used to represent environmental quality status include,
the median or 90th/95th percentiles, in addition to compliance rates to stipulated ambient
standards.

In addition to basic descriptive statistical analysis, the application of multivariate analytical
techniques such as Principal Component Analysis, Factor Analysis and Discriminate
Analysis allow for an assessment of the relative contribution of parameter, temporal/
seasonal factors, sampling site and pollution source(s) to the observed database.

Effective monitoring network design include a reporting system that efficiently and
accurately transmits the environmental information derived from the generated database.
In designing the format and content of environmental reporting, the identification of who
the target reader is hugely important. Hence, reports devised for the general public should
be written in easy-to-understand terms employing descriptive and general environmental
indicators such as the use of indices that can be translated into a descriptive assessment
of environmental quality. On the other hand, more scientifically detailed reports, including
the corresponding database, incorporated with management implications should be the
basis of reports targeted to technical and operational personnel and managers.

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ENVIRONMENTAL MONITORING & ASSESSMENT IN MALAYSIA

Environmental quality monitoring in Malaysia, in the context of a long-term, nation-wide
ambient monitoring network is primarily associated with the Department of Environment
(DOE) under the Ministry of Environment and Water. Monitoring works commenced very
soon after the establishment of the then Division of Environment in 1975 (Renamed as
DoE in 1983), following the gazettement of the Environmental Quality Act 1974.

In realising the importance of adopting a data-driven approach to managing the
environment, the DOE gradually established an ambient environmental quality network,
encompassing air, river, groundwater and marine water quality monitoring stations, as
well as conducting enforcement-related monitoring of various regulated activities.

In the approximately first two decades of its establishment, the environmental quality
monitoring activities were undertaken by DOE officers. In 1995, in the climate of
privatization and greater participation of the private sector in the form of Private
Finance initiatives at that time, selected components of the monitoring works were
outsourced to the private sector, which continued to the present day in the form of the
Environmental Quality Monitoring Program (EQMP) (Figure 3.3). However, monitoring
works related to enforcement and compliance to stipulated regulations remained the
responsibility of the DOE as well as the corresponding proponents of the regulated activities.

1st Environmental Environmental
Monitoring Quality
Concession Monitoring
1995 - June 2017 Program
Environmental (EQMP)
monitoring works (July 2017-
by DOE ~ 1976-1994 Present)

Figure 3.3: Evolution of Ambient Environmental Quality Monitoring Programs Under the DOE

With respect to air quality monitoring networks in Malaysia, in addition to the DOE’s
long term ambient air quality program, the only other long-term, federal-based program
in operation is under the Malaysian Meteorological Department which operates a small
number of air quality monitoring stations.

In contrast to air quality monitoring, several other federal agencies undertake long-
term water quality monitoring programs. Chief among these is the Ministry of Health,
specifically, its Engineering Services Division, which conducts regular monitoring
activities directed to raw water, in particular river water quality in reference to the

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National Guidelines for Raw Drinking Water Quality, as part of its drinking water quality
surveillance program. The Department of Irrigation and Drainage (DID) has also been
conducting ambient water quality monitoring activities as part of its river hydrological
network. However, the number of water quality monitoring stations is rather small,
numbering less than 100 monitoring stations throughout the country.

With respect to state governments, the Natural Resources and Environment Board
(NREB) of the state of Sarawak is one of the very few state governments that conducts
its own ambient environmental quality monitoring program. Another noteworthy example
is the Putrajaya Corporation, the local authority that administers the Federal Territory
of Putrajaya, which has been conducting monitoring works at the man-made Putrajaya
Lake and the surrounding wetlands since the formation of the water body. Other
government agencies conduct ambient monitoring from time to time as part of a specific
study or survey.

In addition to water management state agencies, notably that of the state of Selangor
(Lembaga Urus Air Selangor), several water concessionaires, as suppliers of potable
water representing various states in Malaysia have also established ambient monitoring
networks, predominantly focused on river water quality as raw water to its water treatment
plants. The extent of the network varies greatly, with the state of Selangor having the
most extensive network, including automatic water quality monitoring stations.

Some form of ambient environmental quality monitoring is a common requirement of
the Environmental Quality (Prescribed Activities) (Environmental Impact Assessment)
(EIA) Order 2015. As part of the EIA report, a baseline environmental quality record
is established, which may comprise air quality as well as, depending on the potential
impact of the project, river, lake, marine water quality and soil and groundwater quality.
In addition, noise and vibration monitoring may also be included.

The data generated represent the quality of the environment before the project is
implemented. In addition, upon approval of the EIA report and as part of the EIA approval
conditions and a component of the accompanying Environmental Management Plan, a
scheduled ambient monitoring program of the relevant environment matrix is conducted
as a basis to ensure the effectiveness of the pollution prevention and mitigating measures
identified in the report. The ambient environmental monitoring quality report is submitted
to the DOE on a scheduled basis.

The assessment of data generated from an ambient environmental quality monitoring
network is generally based on the corresponding ambient standards which includes the
following:

i. National Water Quality Standards;
ii. Malaysian Marine Water Quality Standards and Index;
iii. National Lake Water Quality Criteria and Standards;
iv. National Groundwater Quality Criteria and Standards;
v. National Natural Recreational Water Quality Standards and Natural Recreational

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Water Quality Monitoring Guidelines (Marine & Freshwater);
vi. Malaysia Ambient Air Quality Standards;
vii. The Planning Guideline for Environmental Noise Limits and Control; and
viii. The Guidelines for Noise Labelling and Emission Limits of Outdoor Sources.

Air and noise-related standards are focused on human health, while water-related
standards are generally focused on beneficial use as well as the protection of ecosystems.
The data generated from ambient environmental quality monitoring programs are
presented in reports that are may be available to the general public as exemplified by
the DOE’s Environmental Quality Report which is published annually.

THE ENVIRONMENTAL QUALITY MONITORING PROGRAM

As can be seen in Figure 3.3, the Environmental Quality Monitoring Program (EQMP)
represents the continuation of the nationwide environmental quality monitoring role of the
DOE. With the exception of groundwater quality monitoring works, which is carried out
by DOE officers, all other ambient monitoring activities under the DOE is encompassed
in the EQMP.

As with the previous monitoring program, the EQMP adopts a Private Finance Initiative
(PFI) model, in which the appointed private entity is wholly responsible for developing
and implementing the program, based on the monitoring network designed by the DOE.
Specifically, the objectives of the EQMP are as follows:

i. Provides the database that forms the basis of managing the environmental quality
of the nation;

ii. Forms the basis for assessing effectiveness of management strategies and action
plans;

iii. Performs as an early warning system related to specific sensitive receptor;
iv. Aids enforcement activities; and
v. Provides model inputs for predictive capability.

The EQMP, which encompasses an air quality monitoring network, as well as a river and
marine water quality monitoring network, is ultimately aimed at the protection of human
health, the nation’s water resources and its rich marine biodiversity and resources. The
monitoring network comprises both continuous monitoring stations as well as manual
monitoring stations, the former allowing for the transmission of near-real time data
while the latter involves sampling activities and laboratory analysis, as well as in situ
measurements at designated locations throughout the nation.

In addition to the stationary monitoring stations, the program also includes mobile
monitoring facilities that are deployed upon incidents of pollution to provide timely data
related to the incident aimed at identifying source(s)/ cause(s), as well as assessing
impact and recommending management and remedial action plan.

85

The parameters measured by the continuous and manual modes of monitoring as well
as the mobile facilities represent the main environmental quality parameters associated
with the respective ambient environments.

Data from all the monitoring network is transmitted to the Environmental Data Centre
(EDC), which functions as a data management and reporting facility. Key features of
the center include QAQC, data analytics and visualization, reporting environmental
modelling, as well as operation monitoring modules.

QAQC protocols adopted in the EQMP is based on the USEPA’s Quality Assurance
Project Plan (USEPA, 2002), encompassing standard operating procedures based
on internationally-recognised methods, field and laboratory operations, automatic
monitoring operations as well as data management, analysis and reporting.

Data generated by the EQMP not only allows for both short, mid- and long-term action
plans and management strategies to be formulated and assessed, but is also used for
the day-to-day operations of the DOE. In aiding enforcement activities for example, the
program provides the following functions:

i. Alerts from the continuous monitoring network;
ii. Notification of pollution events & in situ data from manual monitoring network;
iii. Reports of exceedances from respective standards;
iv. Investigative studies; and
v. Special Studies.

Data from the EQMP also comprises a major component of the yearly Environmental
Quality Report which provides key data and information on the environmental quality
status of the nation to the general public. In addition, the data is also used in international
reporting, including the WHO Global Ambient Air Quality Database.

In recognizing the dynamic nature of environmental quality monitoring networks,
particularly as it pertains to a nation-wide program, the EQMP is reviewed from time to
time in response to changing priorities of an increasingly data-driven demands of the
management approach of the DOE.

The following sections provide a brief description of the respective components of the
EQMP.

The Air Quality Monitoring Network

The air quality monitoring network of the EQMP comprise 65 continuous air quality
monitoring stations (CAQM), 3 mobile stations and 14 manual stations located throughout
the nation (Figure 3.4).

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Environmental Quality Monitoring & Assessment

Green = Sub urban
Purple = Urban
Yellow = Industry
Light purple = Rural
Red = Reference / Baseline

Figure 3.4: The Air Quality Monitoring Network of the EQMP

Data from the CAQM stations provide near real-time air quality data which is transmitted
to the EDC on a scheduled basis. The monitoring stations are categorised in relation
to its location as urban, suburban, industrial and rural. In addition, one CAQM station
represents background air quality characteristics. The set of parameters measured is
dependant on the category of the station. However, all stations measure particulate
matter (PM10 and PM2.5).

Figure 3.5: A CAQM Station (l) and a Manual Air Quality Monitoring Station (r)

The air quality parameters measured at the CAQM stations are generally considered as

the key parameters related to assessing ambient air quality and are included in most

of the national ambient air quality monitoring Inneatwdodritkiosnt,hmroeutgehooroultogthicealwpoarlrda:mPeMte1r0s,
PM2.5, SO2, SOX, NO, NO2, NOX,, CO and O3.
(Temperature, relative humidity, wind speed, wind direction & barometric pressure) and

solar radiation are also measured. At selected stations, ozone precursors, comprising

numerous volatile organic chemicals (VOCs) are monitored and assessed in relation to

the prevailing ground level ozone levels.

87

All the related equipment in the air quality monitoring network are certified by
internationally-recognised agencies such as USEPA, TÜV and MCerts.

In addition to the fixed monitoring stations, near-real time data is also available from the
3 mobile air quality monitoring stations. The latter is equipped with the complete suite
of equipment to measure a comprehensive list of air quality parameters. The mobile
units are deployed in instances of pollution events or when a particular study need to
be undertaken.

Figure 3.5: Mobile Air Quality Monitoring in the EQMP

While the continuous modes of monitoring of the fixed and mobile stations generate

data associated with the air matrix, the manual stations in the air quality monitoring

network provide data that is associated with particulate matter in the air. The 14 manual

stations comprise high-volume samplers pthaartticfuunlactteiomn atottecroilsleacnt abloytshePdMfo1r0 haenadvPy Mm2e.5taolns
a predetermined schedule. The collected

and hydrocarbon.

Data from the CAQM and the mobile stations is used to generate hourly Air Pollutant
Index. The information from the CAQM stations is made available to the general public
via the website APIMS (Air Pollutant Index of Malaysia) as well as the mobile application,
MyIPU.

The near-real-time generation of air quality data from the CAQM network represents
elements of an early warning system with regards to levels of air pollutants that may
exert a harmful effect on human health. Such alerts are incorporated into the network
and allow for the timely and appropriate management action to be taken. In a similar
way, the air quality data related to the deployment of the mobile stations is aimed at
providing information pertaining to potential health impact of the surrounding population
at the location of the deployment.

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In addition to providing data and information to the general public, data from the air
quality monitoring network of the EQMP, including data from the manual sampling is
analysed using appropriate statistical tools to provide a more detailed assessment of the
status and trends of air quality in Malaysia both to address local as well as transboundary
air pollution issues.

The River Water Quality Monitoring Network

The monitoring of the nation’s major river basins in the EQMP comprises 30 continuous
river water quality monitoring stations (CRWQM), 1353 manual river water quality
monitoring stations (MRWQM) as well as 4 Rapid Response Teams (RRT) to be
deployed to undertake investigative sampling or special study (Figure 3.6). The network
covers199 river basins comprising 692 rivers throughout the country.

The CRWQM network provides continuous river water quality data which is transmitted
to the EDC on a scheduled basis. The network comprises monitoring stations that are
located upstream of intake points in major river systems in Malaysia with the exception
of the station located at Sg Klang which is aimed at providing data to assess the
effectiveness of the River of Life project.

Legend:
CRWQM Station
MRWQM Station

Figure 3.6: The River Water Quality Monitoring Network of the EQMP

Data from the CRWQM stations is used to assess the raw water quality before it
reaches the water treatment plant. In this regard, a target of Class II, consistent with
raw water quality suitable for conventional treatment, is the desirable water quality. Pre-
determined alert levels allow for the timely recognition of potential pollution event that
may compromise the treatment capability of the downstream treatment plant.

As with all the data from the EQMP, the water quality data is transmitted to the EDC on
a scheduled basis.

89

Figure 3.7: Continuous River Water Quality Monitoring Station

The river water quality parameters measured at the CRWQM stations are generally
considered as the key parameters related to the assessment of river water quality and
includes parameters that allow for the generation of the Water Quality Index (WQI). The

parameters measured are given in Table 3.6.

Table 3.6: Measured Parameters at the Continuous River Water Quality Monitoring Station

NO EQUIPMENT PARAMETER

1 Water quality Temperature, pH, Conductivity, Salinity (derived from
multiparameter sonde conductivity and temperature), Dissolved Oxygen,
Turbidity, Total Suspended Solids (TSS), (derived from
turbidity), Ammoniacal-N, Depth

2 Spectrometer Chemical Oxygen Demand (COD), Biochemical
Oxygen Demand (BOD), Total Organic Carbon (TOC),
3 Acoustic Doppler Current TSS, Nitrate, Hydrocarbon
Profiler
Flow, Discharge

The MRWQM network numbering 1353 monitoring stations located at major rivers,
allows for the comprehensive assessment of the nation’s river water quality. Each of the
station is monitored 6 times a year, encompassing both high and low flow regimes. At
each station, in situ measurements are taken and water samples collected, preserved
in the appropriate manner and sent to a accredited laboratory to be analysed. In total,
34 water quality parameters are measured, comprising WQI parameters, heavy metals,
organic and inorganic chemicals as well as microbes. The number of water quality
parameters are increased to represent all the parameters defined in the National Water
Quality Standards every three years to provide an even more comprehensive database.

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Figure 3.8: Manual River Water Sampling in the EQMP
In addition to conducting the monitoring works at the designated MRWQM stations,
signs of pollution incidents based on clearly defined indicator observations well as in situ
measurements are also reported for timely action by DOE officers.
The RRT is equipped with water quality monitoring paraphernalia, including the ability to
deploy continuous monitoring systems. The team is deployed upon incidents of pollution
or to undertake special studies, associated with water pollution. The ultimate goal of
the team is to generate sufficient and appropriate data to allow for i) the identification
of the cause or source of the incident, ii) the identification of the nature, temporal and
spatial extent of the impact of the incident and iii) recommendations of mitigating and
preventive measures.
Data from the river water quality monitoring stations is analysed using appropriate
statistical tools to provide a detailed assessment of the status and trends of river water
quality in Malaysia.
The Marine Water Quality Monitoring Network
The monitoring of the nation’s marine waters in the EQMP comprises 10 continuous
marine water quality monitoring stations (CMWQM), 388 manual stations and 7 Rapid
Response Teams (RRT) to be deployed to undertake investigative sampling or special
study (Figure 3.9).

91

Classes Class IV
Class I Class V
Class II

Figure 3.9: The Marine Water Quality Monitoring Network of the EQMP

The CMWQM stations provide continuous marine water quality data which is transmitted
to the EDC on a scheduled basis. The monitoring stations are located in waters that are
prone to pollution, in particular from oil spillage and discharge as well algal bloom arising
from excessive nutrient levels.

Figure 3.10: Continuous Marine Water Quality Monitoring Station

In addition to general indicators of marine water quality, the parameters measured at the
CMWQM stations are generally associated with the common pollution events that have
and continue to occur at the near coastal waters of Malaysia (Table 3.7).

Table 3.7: Measured Parameters at the Continuous Marine Water Quality Monitoring Station

NO EQUIPMENT PARAMETER

1 Water quality Temperature, pH, Conductivity, Salinity (derived from
multiparameter sonde conductivity and temperature), Dissolved Oxygen,
Turbidity, Total Suspended Solids (TSS) (derived from
turbidity), Depth

2 Fluorimeter Polycyclic Aromatic Hydrocarbon, Coloured Dissolved
Organic Matter (CDOM), Chlorophyll-a

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Data from the CMWQM stations is used to assess the marine water quality in general,
in addition to providing a basis for establishing alerts levels indicating pollution events.
Oil pollution and eutrophic conditions leading to possible algal blooms represents a
common cause of concern. Pre- determined alert levels allow for the timely recognition
of potential pollution event that may compromise the integrity and well-being of sensitive
receptors.

Figure 3.11: Manual Marine Water Sampling in the EQMP

The 388 manual monitoring stations are located at coastal, island and estuarine waters
throughout the nation’s coastline. The list of parameters measured allows for the
comprehensive assessment of the nation’s marine water quality. Each of the station is
monitored 6 times a year. At each station, in situ measurements are taken and water
samples collected, preserved in the appropriate manner and sent to an accredited
laboratory to be analysed. In total, 28 water quality parameters are measured, comprising
MWQI parameters, heavy metals, organic and inorganic chemicals as well as microbes.

In addition to conducting the monitoring works at the designated MMWQM stations,
observations of pollution incidents are also recorded based on clearly defined indicator
observations well as in situ measurements.

The RRT, equipped with all the marine water quality monitoring paraphernalia, including
the ability to deploy continuous monitoring systems are brought into action upon incidents
of pollution as well to undertake special studies usually associated with water pollution.

The Environment Data Centre

The Environmental Data Centre (EDC) is the database management system of the
EQMP. All the data from the EQMP network is transmitted, stored, analysed and
displayed in the EDC. Key elements of the EDC include the QAQC protocols, data
analytics, data visualization and reporting. Integrated in the database architecture are
the relevant spatial information representing key elements of decision support capability.
In addition, key operational parameters such as data transmission is also monitored at
the EDC. Alerts arising from potential pollution events are also sent from the EDC for
follow up-action by the DOE.

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Figure 3.12: The Environment Data Centre

The EDC comprises a server farm, command centre and a disaster recovery site for the
purpose of storing redundancy software and environmental data.

In addition to designated DOE officers who have differing levels of access to the
database, the EQMP data is also made available to state governments. Furthermore,
as stated above the general public have access to Air Pollution Index data via the DOE
website as well as through smart phone application. Data from the EQMP network may
also be applied for to the DOE by consultants and related environmental management
practitioners.

CONCLUDING REMARKS

The relevance of environmental monitoring in environmental science, policy and strategic
design and in managing the environment as a whole is well established. Indeed, in light
of the increasing environmental issues ranging from local issues such as polluted rivers
that result in potable water supply disruption, to haze episodes that necessitates the
closure of schools in the region, through to the long-term records of atmospheric carbon
dioxide concentration related to global climate change, environmental monitoring
programs continue to be increasingly relevant.

Needless to say, monitoring the environment is a costly affair. As stated above, ambient
environmental monitoring activities are undertaken by several agencies in Malaysia
resulting in an overlap of the database generated, both in terms of parameters as well
as geographically. In addition, in order to carry out a more comprehensive assessment,
data generated from one agency may require related data from other agencies as
exemplified by water quality data from the DOE which complements hydrological
data from Department of Irrigation and Drainage. Hence, a complete free flow of
data accessibility from related agencies would go a long way in allowing for a more
comprehensive assessment of environmental quality in Malaysia.

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In fact, related agencies should really be collaborating at the design stage of monitoring
programs. In order to encourage a greater commitment to monitoring on behalf of
relevant agencies, while at the same time ensuring a cost-effective monitoring program,
the network design should include a collaborative effort on behalf of various stakeholders.
Hence, a rationalization of monitoring network that serves the needs of multi stakeholders
would go a long way to establishing a cost-effective, long-term monitoring programs
as a basis for data-driven management of the Malaysian environment. Furthermore,
such programs should be designed to be flexible and dynamic in nature, maintaining
some portions of the network while allowing changes in the network to cater to new
and different priorities, development activities and changes in land use as well as the
potential threats of emerging pollutants. The network should also be reviewed to apply
new monitoring technologies. In addition to the institutionalized monitoring programs
as described above, communities also have a role to play in such activities within their
respective areas. While some activities in this regard do take place, there is a clear need
to encourage and facilitate the development and long term implementation of this so
called Citizen Science programs, particularly, in sensitive areas.

As noted above, assessment of ambient environmental quality data is primarily
undertaken in relation to the corresponding ambient standards. These standards are
adapted predominantly from developed countries such as US, Europe, Canada and
Australia/ New Zealand. There is therefore a need to undertake studies relevant to
the derivation of criteria and standards to better represent the Malaysian environment,
particularly in relation to the tropical aquatic environment, including marine ecosystems.
Local universities and research institutes are well placed to play their role in this regard,
towards deriving standards that are based on local conditions coupled with the use of
indigenous test species and ecosystems.

With regards data analysis, the necessity of the availability of data representing relevant
environmental quality parameters, related hydrological and meteorological parameters
as well as spatially defined pollution sources and sensitive receptors is essential to
contribute meaningfully to a data driven management of the environment. Statistical
tools ranging from basic descriptive statistical analysis to multivariate analysis are
considered fairly routine in analysing large database. Looking ahead, the availability
of big data technology to gather huge sets of data which are subjected to analysis in
identifying trends and patterns as well as relationships should be applied to environmental
management.

It should be emphasized that environmental monitoring is also the responsibility of
those related to the potential pollution sources. More emphasis should be placed in this
regard. In addition, while such monitoring activities may be part of regulatory obligations
with regards to individual premises and/or prescribed activities, other stakeholders, in
particular local authorities and industrial zone associations should also play a role in
environmental monitoring within their respective jurisdictions. Compliance monitoring
should really be viewed beyond adherence to regulatory threshold but rather as an
integral part of self-regulation.

95

REFERENCES

ANZACC, 2000. Australian guidelines for water quality monitoring and reporting,
Australian and New Zealand Environment & Conservation Council, Agriculture and
Resource Management Council of Australia and New Zealand

Batram, J & Ballance, R, (Eds) World Health Organization & United Nations
Environment Program, 1996. Water quality monitoring: A practical guide to the design
and implementation of freshwater quality studies and monitoring programs.

CCME, 2011. Ambient Air Monitoring Protocol for PM 2.5 and Ozone – Canada-wide
Standards for particulate matter and ozone, Canadian Council of Ministers of the
Environment, Winnipeg, Manitoba, Canada

CCME, 2012a. Guidance Document on Achievement Determination: Canadian Ambient
Air Quality Standards for Fine Particulate Matter and Ozone, Canadian Council of
Ministers of the Environment, Winnipeg, Manitoba, Canada

CCME, 2012b. Guidance Document on Air Zone Management, Canadian Council of
Ministers of the Environment, Winnipeg, Manitoba, Canada

Chapman, DV, World Health Organization, UNESCO * United Nations Environment
Program, 1996. Water quality assessments: A guide to the use of biota, sediments and
water in environmental monitoring, 2nd ed, London

EU, 2016. https://www.eea.europa.eu

https://asq.org

ISO 5667, 1980. Water quality- Sampling- Part 1: Guidance on the design of sampling
programs

Jiping Jiang & Yi Zheng, 2020. A comprehensive review on the design and optimization
of surface water quality monitoring network, Environmental Modelling & Software, 132

Lovett, GM, Burns, DA, Driscoll, CT, Jenkins, JC, Mitchells, MJ, Rustad, L, Shanley, JB,
Likens, GE & Haeuber, R, 2007. Who needs environmental monitoring? Frontiers in
Ecology and the Environment, 5(5), 253 - 260

UNEP/WHO/UNESCO/WMO, 1981. Program on global water quality monitoring and
assessment, World Health Organization. Community Water Supply and Sanitation Unit.
UNESCO & Global Environmental Monitoring System. GEMS/WATER Operational guide

US EPA, 1998. Guideline for ozone monitoring site selection, Report No EPA-
454/R-98-002, United States Environmental Protection Agency, Washington, DC, USA

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US EPA, 2002. Guidance for quality assurance project plans (EPA QA/G-5), United
States Environmental Protection Agency, Washington, DC, USA

US EPA, 2003. Elements of a state water monitoring and assessment program, United
States Environmental Protection Agency, Washington, DC, USA

US EPA, 2005a. Review of the National Ambient Air Quality Standards for particulate
matter. Policy assessment of scientific and technical information, United States
Environmental Protection Agency, Washington, DC, USA

US EPA, 2005b. Analytical techniques for technical assessment of ambient air
monitoring networks: Guidance document, United States Environmental Protection
Agency, Washington, DC, USA

WHO, 2000. Air quality guidelines for Europe: Second Edition, World Health Organization

APPENDIX 1

Effluent, Emission and Noise Quality Regulation of the EQA 74 Applicable in
Malaysia

NO MATRIX RELATED REGULATION
1 Effluent » Environmental Quality (Sewage) Regulations 2009

2 Emission » Environmental Quality (Industrial Effluent) Regulations 2009

» Environmental Quality (Control of Pollution from Solid Waste
Transfer Station and Landfill) Regulations 2009

» Environmental Quality (Prescribed Premises) (Crude Palm Oil)
Regulations 1977

» Environmental Quality (Prescribed Premises) (Raw Natural
Rubber) Regulations 1978

» Environmental Quality (Clean Air) Regulations 2009

» Environmental Quality (Motor Vehicle Noise) Regulations 1987

» Environmental Quality (Control of Emission from Diesel
Engines) Regulations 1996

» Environmental Quality (Control of Emission from Petrol
Engines) Regulations 1996

97

NO MATRIX RELATED REGULATION
3 Noise
» The Planning Guideline for Environmental Noise Limits and
Control

» The Guidelines for Noise Labelling and Emission Limits of
Outdoor Sources

4 All relevant » Environmental Quality (Prescribed Activities) (Environmental

environmental Impact Assessment) (EIA) Order 2015

matrices

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AUTHOR

Dr Abdul Rani Abdullah has more than 30 years of consulting
experience in the field of water science and management,
encompassing river, lake and marine water quality management.
He began his career as an academician in the Department of
Chemistry, University of Malaya and subsequently joined the
private sector as Principal Consultant in numerous water-related
projects with various government agencies, industries as well as
international organizations. His project experience ranged from
oil spill investigations and establishing national water quality standards and indices,
to designing water quality monitoring network and early warning systems as well as
formulating river and lake management plans.

He is currently the Chief Executive Officer of Pakar Scieno TW Sdn Bhd, the contractor
to the Government of Malaysia in establishing and implementing the nation-wide
Environmental Quality Monitoring Program on behalf of the Department of Environment.
Additionally, he is currently serving as Adjunct Professor at the Faculty of Science &
Technology, Universiti Kebangsaan Malaysia.

Mr. Mohd Faizul Hilmi B. Zulkifli is a Senior Principal Assistant
Director at Department of Environment, Selangor. He holds a
Bachelor Degree in Biochemistry from Universiti Putra Malaysia
and Master Degree in Environmental Assessment and Monitoring
from Universiti Kebangsaan Malaysia. He has more than 20 years
of working experience in environmental enforcement for ensuring
compliance with the provision of the Environmental Quality Act 1974,
which is the primarily legislation dealing with environment protection
and conservation in Malaysia. In his article titled, “Volatile Organic Compound and Their
Contribution to Ground-Level Ozone Formation in a Tropical Urban Environment”, which
published in Chemosphere contribute to further understanding of the distribution of
VOC concentrations and their potential contribution to Ground-Level Ozone formation
particularly in the tropical urban environment.

99