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… take some time to read environmentalist Dr Leong Yueh Kwong's thoughtful response to the draft Special Area Plan for the Garden.
Have you submitted your own response to the draft Special Area Plan? Hurry, the closing date is 14 March. You can print out the feedback form from here.
Now is the time to speak up loud and clear.
First off, a few words on the rationale for the Special Area Plan for the Garden to put it in context.
Well, after the fiasco of the twin 'Leaning Arches of Penang', the Ministry of Tourism said it would not channel anymore money for any projects until there is a valid and publicly acceptable master plan – which is actually a good thing.
The CM was also getting a lot of negative responses to the chopping of trees for the not-needed car park at the garden mall. Moreover, the promise of replanting of trees was not fulfilled until now due to the administrative problem of getting a qualified director for the Garden, given the low pay scale.
A Special Area Plan is actually not the same as a master plan; the SAP is mainly a land-use plan and for development control rather than a master plan. Hence, the confused nature of the proposals in the draft SAP.
Before we move on to Yueh Kwong's comments, a couple of points should be clarified. The Botanic Garden is not the place for a scouts' camping site. The scouts (and I was a scout many moons ago) should be allotted alternative sites for camping – but not at the Garden.
The Garden is also not the place for a rifle club. Many people are under the mistaken impression that the Rifle Club is situated on a neighbouring plot to the Garden. No, from what I gather, the club is 'squatting' on Botanic Garden land.
And please, no more unnecessary concrete structures (including conventions centres!) at the Garden. Enough damage has been done.
Okay, on to Yueh Kwong's comments. It is a bit long but well worth the read:
Overview of the Draft Report
What the master plan should aim for:
1. Identify the main issues and problems facing the PBG in its future development.
The expansion of the gardens from 72 acres to 596 acres is the most significant transformation of the gardens since its establishment in 1884. This poses new problems and challenges as well as new opportunities.
The development and management of the Penang had a number of problems and weaknesses during the course of the last 30 years or so. Part of this is from the increase use of the gardens by the public with over 2 million visitors counted in around 2000. Part of the weaknesses and problems is due to the poor planning and implementation of projects in the gardens, especially in the last 20 years or so. There is therefore a need to understand the problems before any solution is proposed.
2. Correcting mistakes made
The master plan should also be an opportunity for correcting past mistakes in the development, especially in the last eight years. When the expanded area was proposed and gazetted but no accepted master plan in place, a number of inappropriate development and ad hoc projects were implemented. This uncoordinated planning and poor implementation is made more serious when RM7m was allocated to the development of the expanded gardens after the expansion was gazetted in 2004.
3. Identify opportunities
The expansion of the gardens is an opportunity to make use of the new space to meet some of the new challenges such as for biodiversity conservation, education, horticulture and recreation in the coming decades. This means that various projects can be located in various parts of the expanded gardens. The current land use of the new area should be to re-examine afresh and not be mentally bound by what was in these areas.
4. Making bold and innovative solutions for long term and short term development
A master plan should make bold and imaginative solutions to the problems of the expanded gardens and translate the vision and mission into an integrated land use plan and not accept past mistakes as a given constraint to plan around the master plan.
The draft master plan has some positive elements but there are also some serious shortcomings as to their analysis of the issues and problems and hence their proposals for the master plan.
Specific comments on the various chapters of the report
1.0 Chapter 1- Site profile and significance
This chapter is relatively straight forward and has some useful maps and diagrams. The contour maps are particularly useful as they show the potential and constraints of development.
2.0 Chapter 2 on Vision and Objectives
The vision and mission are generally well articulated but these are available in the various documents of the Botanic gardens and other international botanic gardens organisations.
This chapter is also quite straight forward except for the curious inclusion of the Alaska Botanic Gardens as an example in section 2.6. Alaska is climatically, geographically and culturally very different from Penang. Better comparisons would be the botanic gardens of Singapore, Thailand, Indonesia or even Australia. Adelaide Botanic Gardens has recently undertaken a master plan study and Adelaide is a sister city of Georgetown Penang. The master plan of the Adelaide Botanic Gardens is available in the web-site.
In the last few years there had been quite a number of botanic gardens all over the world which are relooking at their development plans in view of the new challenges of the coming decades. The SAP would benefit to look into details of the physical layout plans of some of these master plans and they are available in the internet. However, there is a need to critically assess these plans and also adapt them to the needs of the PBG if the decision is to use some of the ideas in these master plans
The list of possible plants for ex-situ conservation in box 2.3 seems to be just copied from somewhere and pasted into the report. Out of the various species for conservation, only 2 species are from Penang. The Dipterocarp tree species are from various states in Malaysia and best conserved in those states and not in Penang. In any case, tree species would be better conserved in the Penang National Park, Rimba Reckreasi in Telok bahang and the forest reserves. The PBG should concentrate on endemic species and endangered species in Penang, such as trees in Penang Hill, such as Maingaya, or the various species of herbs such as Didymorcarpus of the Gesneriaceae or the Paphiopedelium (slipper orchids).
3.0 Chapter 3 on The Penang Botanical Master Plan
There are a number of glaring mistakes in this section, which is the most important part of the SAP study as the proposals and layout plan would be the most difficult to change if accepted by the state planning committee. There are many gaps and weaknesses in the proposed draft master plan as a development plan for PBG (Penang Botanical Gardens) for the coming years.
In 3.1 of the draft SAP, it states that the Clive Justice Mater Plan is a plan that does not include the new expanded area. This is wrong. The whole idea of getting Clive Justice to Penang was to propose development in the expanded area. In the CJ master plan, there was some minor mention made of the existing old gardens. The main thrusts of the CJ plan were proposals for the development of the expanded area. This mistake of the SAP brings into doubt whether the consultants had actually seen the Clive Justice Plan which they say forms the framework of their SAP proposals. Perhaps the Botanic Gardens Department and the JPBD had not made available the Clive Justice Plan to the consultants.
However, the SAP report had stated earlier in Chapter 1 that some of the more recent developments such as the location of the surau and new office did not conform to the plan, presumably the Clive Justice Plan. The consultants should make another attempt to familiarise themselves as to what the Clive Justice Plan proposed and then make proposals to update or change the proposals which had actually been approved by the State Planning Committee earlier.
The SAP and proposed draft master plan rightly concentrated their proposals on the flat areas of the expanded gardens which started from the old gardens gate to the new entrance beyond the moon gate. This is stated to be 110 acres of flatland in their chapter 3 of the draft report.
However, the proposals appear to accept the current existing situation as given and cannot be changed even though they are clearly mistakes. The consultants had propose new infrastructure to surround the mistakes such as the large open drain in the water garden mall. However, proposals for infrastructure development should be more innovative and bolder in its approach to planning of botanic gardens in the South East Asian region. The trends in the design of botanic gardens such as in Chiang Mai, Thailand should be looked at for ideas on the design and layout of the gardens, such as the design of water lily ponds and plant houses. Other examples would be Singapore which is building a new gardens by the sea as well as renovating parks of their gardens such as the evolution garden.
The consultants should critically review the existing infrastructures in the gardens and see if these meet the requirements of the stated objectives and mission of the expanded PBG.
3.1 Land use of the 110 acres of flat land
The expanded area of the botanic gardens would require a re-conceptualise the land use of the gardens. The centre of gravity of the gardens has shifted from the lawns of the inner ring road to the new garden and water mall. The new central area links up various parts of the garden such as the quarry area, the formal garden, the old garden, the bambusetum as well as the walkways from the new administrative building and entrance. There should be a visual linkage of the new centre to the other parts of the gardens whenever possible.
The new area of flat land in the new gardens stated by the SAP is 110 acres which is 2-3 times more than the developed areas of the old garden. This area is mainly from the new entrance of the gardens to the old entrance as well as the quarry garden and bambusetum. The potential development and redevelopment areas includes the Garden Water Mall, Bambusetum, the eco-stream walkway, the surau and the new proposed propagation centre near the hawker complex.
The new proposals of the SAP include the Malay Kampong house and ethno-botanical museum by the bambusetum.
On the left side of the road from the Youth Park will be will be the new car park, new administrative office and visitor centre and rifle club.
The ex-PDC Quarry area forms another cluster of proposed development, though the area is not as flat as the central area but scenic as it is on a gentle incline and the old quarry forms a natural amphitheatre. There is a small waterfall on the quarry face and a stream that flows down from it to the central part of the gardens.
3.2 Omissions in the SAP
There is a narrow linear strip of land from the new office through the moon gate to the Rifle club which has not been considered for any development proposals. This strip of land is shaded by tall trees and MPPP had built a brick walkway from the Moon Gate to the Rifle Club. There is a great potential of improving the walkway and also the introduction of plants that require shade. Though most of the land is quite steep, there are sections that are flat and can have collections of plants. The path should be visually be integrated with the road.
The issue of the moon gate and footpath up Penang Hill via the moon gate has been totally ignored. The path is part of the expanded gardens and the path is badly eroded. This can be upgraded and improved. The management of the footpath should be given some attention, especially when trekkers come down past the closing time of the gardens.
3.3 Traffic Management, car parking and circulation in the PBG
The problems of car parks, traffic management and visitor circulation in the PBG is one of the most serious issues facing the gardens. In 2009, the Botanic Gardens Department had made a request to the Exco of Traffic Management and local Government to help resolve the traffic and parking problem. The MPPP was assigned to the task. However, no action was taken and it was suggested that the Penang Transport Master Plan study and/or the SAP would deal with this problem. It is well known that there is a lack of parking space during peak hours of mornings and evenings and cars are parked all over the road sides. With over 2 million visitors a year, there had been no proper study on the parking requirements and how traffic is to be managed. On special occasions such during the flower shows and musical events, the traffic is chaotic and most people who had experience the gridlock have avoided going to such events. The Thaipusum festival also causes traffic gridlock and cars are banned in the waterfall road for the two days.
The SAP gave a figure of 100 to 120 parking lots to be created near the new office. What is the basis of such a figure? Has there been a traffic study? If so, is there a separate technical report available for review?
3.4 JKR Road up Penang Hill
The expanded area added to the PBG now includes the JKR road up Penang Hill. When the JKR road was built in the 1970s, it was outside the PBG. What to do with a public road that divides up the garden poses challenges in traffic management in the short term and relocation of the road in the long term.
The SAP appear to assume that the Penang Hill road is permanent and cannot be changed and even suggests that the cars up the hill be registered. There are various problems in the traffic management such as where the JKR check point would be – would it be outside the gardens' premises such as at the new entrance? Would the Gardens' department have any role in traffic across its premise?
However, new thinking is required. One earlier proposal was for JKR to realign the road to be outside the Gardens. In fact, JKR had promised to look into this issue a few years ago but said that they need clearance from their HQ in KL. Looking at the contour map, there is a possibility of the road coming out from the area of the youth park. The SAP should look into the issue of the JKR road on the short term and long term solutions if the PBG is to maintain its integrity.
3.5 Relocation of areas for annual flower show and infrastructure requirements
The usage of the PBG as a centre for annual flower shows and exhibitions and special events is now well established and likely to continue into the future. However, No infrastructure had been proposed to cater for such events in the SAP, such as flower display areas, shelters, storage areas, etc for such events. There is a brief reference in the SAP that the exhibition areas could be near the quarry park area.
In an earlier plan, the Clive Justice Master Plan, one such area was proposed near the formal garden but the SAP appears to be unaware of such a proposal. One area that would be suitable would be the present nursery area which is sizeable and next to the formal garden. If need be, the flower exhibition area can spill out to the area near the bambusetum and the present cafeteria which can be modified to be part of the administration and exhibition area for the flower show.
The relocation of the plant nursery should be seriously reconsidered. One location could be across the stream where the Malay house is. There would not be such a big area if the PBG Department gives up its function of supplying plants to official functions to the newly created MPPP Department of Landscaping.
3.6 Musical festivals and events
Similarly, the PBG is used for musical events such as musical festivals, and the problems and implications are not analysed, such as parking, infrastructure, damage to lawns, etc. The area that had been used for musical festivals causes serious damage as the lawns do not have subsoil drainage and in rainy periods when the flower shows and musical events were held had caused much damage to the lawns which need months to repair.
3.7 Rectification of mistakes in recent developments in the Gardens Mall area
The rectification of mistakes made over the last eight years should be one of the major concerns of the SAP. However, the Master Plan chapter 3 does not appear to see this as part of their scope.
a. The water garden mall area
This is the new geographical centre of the expanded botanic gardens, and is the convergent point of the old botanic gardens, the quarry section of the new gardens, the formal garden and bambusetum, and the pathway from the new entrance of the gardens. As such, this should be the show case of the new gardens. The proposed water gardens could have been such a show case, but the poor design and concept have made this difficult if not impossible.
b. Landscaping and tree planting of water garden mall
However, the recent development of the garden mall has caused serious damage to the central park of the gardens by building a large number of car parks in this area and the cutting down of large trees (of more than 70-80 years old) in the construction of the car parks in a car-free gardens.
c. Destruction of the natural stream from the water catchment from the quarry area
The stream that came out from the Quarry had been canalised in the construction of the water garden mall. The natural stream had been made into a large open drain by the side of the ponds. This engineering approach is totally insensitive to the natural ecosystem and the requirements of a botanic gardens which should have as many natural features as possible. The large open drain is dangerous and the risk of people falling in is very real. The sump built at the beginning of the drain to direct the water flow is now a rubbish trap and also a source of danger to visitors. There is no attempt in the SAP to rectify such mistakes. The stream should be recreated and the drains covered up. The whole landscape of the ware garden mall will have to be redone.
d. Car parks in the water garden mall
The construction of the many car parks in the garden mall is the result of the complete lack of understanding of the requirements of a botanic gardens. The consultants did not even know that the PBG had been extended and they appear to assume that they are designing for a public park in front of the botanic gardens. The CJ master plan of the gardens envisages a car free garden. The design that was implemented in 2010 assumed that they have to provide for car parking for public as well as the rifle club.
In the construction of the car parks and road system, large trees were chopped down illegally and against the orders of the MPPP. In the public protests that followed, the PBG and the JPS (the implementers of the project) promised to plant 10 trees for every one chopped down. More than two years have passed and not one tree has been planted.
There is a need to completely redesign the critical mall area, to plant more trees, remove the car parks, restore the stream, put in more ponds for water plants and establish visual continuity with the quarry area, formal garden, bambusetum as well as the original garden.
e. Quarry recreational park
The quarry recreational park was a project to show some progress in the development of the gardens before the 2004 general elections. The intention was to increase the amount of recreational space for the public. The activities would include tai chi exercises, line dancing, etc.
While there is nothing wrong in providing recreational activities in a multi-use botanic gardens, the planning and implementation has been poor and did not attempt to be part of the existing Clive Justice Master Plan. The area was part of the old PDC quarry and as such has no soil. The soil that was brought in for the quarry recreational park was limited and forms a thin covering over the rock bed. There was not enough soil to support the growth of trees and planting holes were created for the planting.
Originally, because of the lack of soil, two large shallow reflective lakes at two different levels were proposed. However, the choice of trees had no botanical rational and of limited botanical value or interest. There would be a need to relook into the replanting of trees in the area.
3.8. Other Potential areas for development
a. Bukit Chenana
There is a reference to a "ridge trail" in the gardens. This appear to refer in part to an area known as Bukit Chenana, accessible both by the JKR hill road as well as climbing up the water fall which is described as dangerous and difficult. Bukit Chenana has the cement and brick footprint of a former house and mistakenly reported in the SAP as a possible location of a house of a former director of the gardens, Charles Curtis. This is wrong. The house is by a private individual built sometime in the 1920s or 1930s. Tun Dr. Lim Chong Eu had suggested in the 1980s that Bukit Chenana be made into a lawn of the PBG and plants requiring a slightly cooler climate may be able to do well. This suggestion was not taken up but it is a possibility and a lookout point be built at the end of the ridge as there is a good view of the waterfall of the gardens from there. Some pergolas could be constructed there for climbing plants to enhance the area. Outdoor furniture could also be placed there.
b. The Curtis trail
This trail was constructed in the 1980s from the water lily pond to the site where there was a house of Charles Curtis. The footprint of the house is still evident in some parts. There is a flat area of about half an acre and there had been a proposal in the 1980s to put a lawn for epiphytic plants there. On the way down the trail, there is a good viewpoint of the waterfall but this has been obscured by tree branches. It should be possible to remove some of the lower branches to get a view of the waterfall from parts of the trail. Platforms if constructed would probably obviate the necessity of too much trimming of the trees. Having some look out points along the trail and some plant collections on the peak would add interest and increase the usage of the Curtis trail which was built by JKR
3.9 National biodiversity Centre in the Penang Botanic Gardens
There is a brief mention of the PBG as a national biodiversity centre but no provision in the layout plan for such a centre. The proposal for two national biodiversity centres for Malaysia was made at the Council of Biodiversity and Biotechnology. The Prime Minister who chaired the Council proposed in 2006 that the Penang Botanic Gardens be a National Biodiversity Centre and this was recorded in the minutes.
A follow-up by the PBG department with the Ministry of Science and Technology with a draft proposal for some start up funds resulted in a promise to allocate RM3 million from EPU. However, since the PBG does not have the expertise to plan, develop and manage the National Biodiversity Centre, it was decided that the proposal should wait until the 12 graduate level staff asked for by the PBG Department was approved.
The establishment of a National Biodiversity Centre in the PBG would boost the development of the scientific program of the gardens and also ensure regular funds from the federal government for the PBG. A suitable location for the National Biodiversity Centre would be the present rifle club.
4.0 Chapter 4 on Tree Maintenance Policy
The scope of this chapter on tree maintenance is too narrow and does not really belong to a SAP and master plan. In developing botanic gardens, the scope should be on planting policy for the gardens for botanical, scientific, educational, horticultural and conservation purposes rather than tree maintenance. The character of botanic gardens is determined largely by the type of plant collections in the gardens. It includes the choice of trees but also other plant collections, such as ferns, hibiscus collection, orchids, gingers, climbers, epiphytic plants, etc. How these plant collections are to be located and arranged is the subject of botanic and horticultural policy discussion and decision by the experts and specialists. This issue on the kind of plant collections had been discussed in some detail in the Review of the Development and Management of the Penang Botanic Gardens (2007).
The planting policy in Chapter 3 is so general that it is of little use in determining what the gardens should emphasise on. Is the planting policy to be based on taxonomic and botanical criteria or landscaping requirements or combination of both? What would be the balance to aim for?
The chapter 4 of the SAP on tree maintenance, though important should probably be in an appendix to the SAP as they are on guidelines on how not to damage trees during construction and where to plant some of the trees.
4.1 Which State Exco and which Ministry should the Penang Botanic Gardens be under?
This issue is of some importance as this is related to the long term funding from the state and federal level. Though the PBG Department is a government department and falls under the charge of the state secretary, it is also overseen by an Exco member of the State government. There had been no consistency as to which portfolio of the state government the PBG should be. It had been assigned to the Exco for tourism, for environment and for agriculture.
For the past 20 years or so, it had been assigned to the Exco for tourism or environment on the grounds that tourism is an important economic activity of the state and the PBG is one of the top tourism destination. As such, there is usually more funds available through the Ministry of Tourism. However, for staffing, it had been through agriculture as the officers to the gardens had been assigned through the Ministry of Agriculture. This is perhaps the reason as to why almost all the senior staff had an agriculture background and training.
With such an ambiguous administrative relationship, there is no ministry at the federal which is responsible for the allocation of funds to develop the PBG as a botanic gardens such as from the five year plans. The Ministry of Tourism had channelled funds to the gardens as tourism is one of the missions of the PBG but it is only meant for tourism-related projects.
With the establishment of a botanic gardens and a national biodiversity centre in the Forestry Research Institute (FRIM), the PBG should perhaps follow the example of FRIM and be placed in the Ministry of Natural Resources as the lead ministry and the other ministries would play important but supporting roles. Tourism-related projects or horticultural projects can continue to be funded from the Ministry of Tourism or the Ministry of Agriculture. The Ministry of Local Government through its landscape programs can also contribute to the landscaping development of the gardens.
At the state level, the Exco for the development and management of the PBG should be reviewed to see if the Exco for agriculture or local government or environment would be a more appropriate portfolio for the PBG to be in. Another possibility could be the assigning of a Deputy Chief Minister as the gardens is a multi function gardens, with education, scientific research, conservation, horticulture, recreation and tourism among the gardens' functions.
5.0 Chapter 5 on Institutional and Funding Framework
This section summarises the various proposals made over the years on how the staffing should be strengthened and organised.
5.1 Role of Management Committee of the PBG
One problem that needs to be looked at again is the designation of the Botanic Gardens Management Committee that would be responsible for the development and management of the PBG. This committee is usually chaired by an Exco member.
It had been pointed out earlier (about 8-9 years ago) by the PBG Department is that as a government department, it is anomalous to have a management committee which has non- government members such as from the universities, research organisations, civil societies and interested individuals to manage the garden which already has a director. A better designation is to have a botanical gardens board, like that of some other gardens in the region. Some have a board of trustees or advisory board. The powers of such a board would need to be spelt out so that there is no ambiguity as to the responsibilities of the board and the director of the gardens.
5.2 Review or scientific committee for the PBG
One issue that had come up in the last few years of project implementation is the critical role of review of projects by a competent review panel, with an understanding of what botanical gardens should be. AT the present moment, there are a number of serious weaknesses in the way projects are implemented which had caused so much public dissatisfaction and discontent.
5.3 Decentralisation of decision making for PBG
At the present moment, the selection of staff as well as consultants for the design and implementation of projects is done in KL. The implementation of projects is by other government departments such as the JKR and JPS. For example, the implementation of the eco-stream walkway, administrative building and water garden mall is by the Department of Irrigation and Drainage (JPS). The approach of these departments is strictly engineering and has very little considerations or inputs from botanists, horticulturalists, or ecologists. This has resulted in natural streams being made into drains and large areas of tarmac for car parks and indiscriminate cutting of large and old trees. This is seen in the eco-stream walkway and the large drains in the gardens water mall.
5.4 Role of Botanic Gardens Department
The botanical gardens development projects should have to be vetted and approved by the Botanic Gardens Board and also their scientific panels which have the expertise and knowledge of what the requirements of botanic gardens are.
The proposed development should also be in conformity to the accepted master plan so that it is part of an integrated plan. Public participation should be required for major development projects.
6.0 The next step forward
6.1 Strategic Development Plan of the next decade.
Public participation is an essential part of the process of creation of a master plan of a public institution of great community and historic value. Public acceptance of the master plan would ensure that there is no dissatisfaction and protests which had occurred over the years. Up to this point, the SAP draft had only been shown to the various government departments as well as members of the government. This public showing is the first time that the public has seen the proposals.
6.2 Need of a review of SAP and Development Master Plan by a competent review panel
The SAP master plan report would benefit from a review of an expert review panel besides the public. The usual departmental review panel is usually comprised of representative of various governments departments. Usually the departmental comments are based on implications on what is mandated by their various departments.
A review panel should include non-departmental representatives such as universities and other gardens departments within the country in the country and the region.
6.3 Strategic development plan for the PBG and time frame for implementation
The framework of a strategy of implementation should be drafted after the acceptance of the SAP and draft master plan. The strategy of development of the PBG that would help resolve the issues and problems identified for in the short term (five years) and long term (20 years).
6.4 Political will for maintaining gardens integrity
There will be political pressure by special interest groups to resist the SAP and botanic gardens master plan. Notable will be the scouts who want to use the gardens as a camp-site, the Rifle Club who will lobby to stay in their premise though their lease has expired years ago, and commercial vendors who would want to have facilities privatised to them.
All these are long standing issues which are the characteristics of the old style of government and governance culture. These should be resisted so that the PBG can realise its great potential of being one of the premier tropical gardens in the world and an institution which is of pride to the Penang community.
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