EVALUATING MEGAPROJECTS: Joseph Marcel R.

Williams
THE CASE OF FOREST CITY
IN JOHOR, MALAYSIA

EVALUATING MEGAPROJECTS:
THE CASE OF FOREST CITY
IN JOHOR, MALAYSIA
by Joseph Marcel R. Williams
Department of Urban Studies and Planning,
Massachusetts Institute of Technology

Abstract
Large urban megaprojects costing billions of US dollars, erected
with the promise of great economic benefits but controversial due to their
environmental and social impacts, are becoming more common
throughout the world. Most popular in the Middle East and in Asia, such
projects exemplify how forces of globalization engage with urban form.
Urban megaprojects are increasingly pursued by foreign developers
looking to expand abroad, but often face challenges operating in
unfamiliar political and regulatory settings.
Chinese developers, in particular, have global ambitions, but may
come into conflict with local priorities as they extend their reach overseas.
Forest City is a vast luxury real estate development by Chinese developer
Country Garden, on 14 square kilometers of reclaimed land spread over
four islands on the Malaysian side of the Straits of Johor: the strip of water
that separates Malaysia from Singapore. This study uses Forest City as a
case study to investigate the key themes associated with large urban
mega projects and the impacts they have on a region. Among them is the
notion that such projects are considered “exceptional,” and therefore can
bypass traditional planning and development controls. Actors external to
planning and development are suspected of co-opting the process for their
own interests. Evidence collected during fieldwork from July-August 2015
and January 2016 suggests that Forest City fits neatly within these
patterns, and sheds light on the patterns of influence in urban
development throughout the region. The case also suggests several
lessons for Chinese developers operating abroad.

Introduction
A growing number of large urban megaprojects undertaken in
various parts of the world by foreign investors have faced serious

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EVALUATING MEGAPROJECTS: Joseph Marcel R. Williams
THE CASE OF FOREST CITY
IN JOHOR, MALAYSIA

challenges because the developers involved are unfamiliar with the

political and regulatory settings within which they are operating. As
Chinese developers in particular seek opportunities abroad, the potential
for conflict and contestation between local priorities and developers with
international ambitions will probably grow. The case of Forest City in
Johor, Malaysia, illustrates many of these challenges. Dramatic shifts in
the design of the Forest City project occurred after the developer, Country
Garden Holdings Ltd., had begun construction, reflecting the costs
involved in accommodating regulators and responding to harsh reactions
from local, regional, national, and even international actors.
The objective of this thesis is to use the case of Forest City to
explore the government-developer-community interactions surrounding
megaproject development by an international investor operating outside
their home country. This study examines how inter-scalar forces shape the
development process in ways that are not initially obvious to developers
operating on foreign soil.

Statement of need
There has been relatively little research on the development of
megaprojects in Southeast Asia, especially efforts headed by foreign
developers. Yet, we can expect many more such projects in the years
ahead. This case study of Forest City seeks to address both these voids,
and offers a fresh perspective on the growing theme of Chinese
development abroad. The Forest City project is an especially compelling
case because it lies in a trans-boundary setting in the so-called “growth
triangle” 1 of Malaysia, Singapore, and Indonesia. Many more local-global
interactions in urban development are sure to follow. According to
Altshuler and Luberoff, “efforts to realize large-scale investment projects
often provide an unusually revealing window on patterns of influence in
urban development politics.” 2 For Southeast Asia and beyond, Forest City
provides just such a window.

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EVALUATING MEGAPROJECTS: Joseph Marcel R. Williams
THE CASE OF FOREST CITY
IN JOHOR, MALAYSIA

Figure 1. Context map for Forest City. Google basemap

Synopsis of Forest City

For much of its history, Johor Bahru, Malaysia has been a scrappy
border town across the narrow Straits of Johor from booming Singapore.
Located in Malaysia’s southernmost state, Johor, the area shares much of
its history with its dynamic southern neighbor. Over time, though, stark
economic disparities have emerged between the two locations, including
levels of real estate investment. In the past few years, however, Johor has
witnessed a dramatic increase in such investment, including a number of
ambitious real estate projects by Chinese developers. The sheer scale of
these projects is astounding—with housing planned for hundreds of
thousands of people, often involving extensive land reclamation.
Country Garden Holdings Ltd.—a private firm that ranks among
China’s top ten developers—began work in 2014 on a project that was
remarkable even by the standards of other massive projects in Johor. This
new project, named Forest City, hopes to comprise some 2,000 hectares.
It is being built exclusively on reclaimed land in the Straits of Johor.
Recalling recent developments in Dubai, it imagines a luxury community
for hundreds of thousands of people. Targeting “international buyers,” it
would be by far the largest such project in Malaysia. 3 It is reported to be
“very high end,” with “dazzling water features” and a number of destination
attractions. All of this is intended to be within easy access to Singapore via
a second link bridge. 4
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For all this grand vision, the project site was not part of a bustling
metropolis. Instead, it was a rural area dominated by palm plantations and
dotted with small fishing villages. Residents plied their trade along coastal
mangroves. Home to the largest seagrass bed in peninsular Malaysia, the
area had for some time been considered eligible for special environmental
protection. 5 Meanwhile, its proximity to Singapore ensured that any
unusual activity would attract scrutiny from across the international border.
In January 2014, coastal residents were surprised to find barges
dumping large quantities of sand on their fishing grounds. No one in the
community could recall being consulted or hearing about the project; 6 it
was not listed in any local, regional, or federal development plan. No
environmental impact assessment was prepared prior to initiating
construction, despite the sensitivity of the site, the project’s immense
scale, and Malaysian environmental laws. What emerged was that the
Sultan of Johor, the state monarch and an active businessman, had
received a 34 percent stake in the project. 7 There are indications that he
and close associates helped shortcut the formal approval and regulatory
process. Thus, the Johor Department of Environment allowed the project
to move ahead, despite the fact that it was not in compliance with a host of
plans and regulations. 8
Not long after the media caught wind of the project, Singapore
made official inquiries, seeking more information on what was intended.
Officials there were concerned about possible adverse effects on the
hydrology of the Straits, as well as numerous potential environmental
impacts. Singapore joined a chorus of inquiries and critical reactions by
Johor fishermen, opposition politicians, environmentalists, and other
property developers. Many expressed a concern about oversupply of
newly constructed residential and commercial space in the Johor property
market. 9 But by this point, enough sand had been deposited to smother
much of the seagrass bed. Several months after Country Garden began
reclamation, the Malaysian federal DOE issued a stop-work order,
mandating that Country Garden complete a full detailed environmental
impact assessment (EIA) before any further work could proceed on the
project.
This intensive environmental review resulted in significant changes
to the project. It was scaled down by approximately 30 percent and its
landform split into four islands that surrounded, rather than smothered, the
seagrass. 10 A number of “mitigating” measures were required, along with
compensation to local fishermen. The cessation of work gave critics time
to ask more questions of Country Garden and its Malaysian partners. A
public information session in the village of Kampong Pok turned into a
public relations disaster for the developer, when the developer’s
spokesperson announced that there was widespread community support
for the project, and then was attacked by irate villagers. A number of
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THE CASE OF FOREST CITY
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negotiations with important stakeholders followed, resulting in further

modifications to the project.
Around a year after work began, ironically, the Forest City
megaproject was formally approved by the federal Department of
Education (DOE) in Putrajaya. While the halt in construction led to
significant changes, the basic idea of the project emerged intact. At great
cost, however, the developer was forced to assume greater social
responsibility.

Figure 2. Timeline of Forest City case

Role of the Sultan

The Sultan of Johor is one of Malaysia’s nine traditional monarchs,
each of whom acts as a steward of Islam for their respective states. As
constitutional monarchs, the Sultans do not participate directly in
governance, but do have some limited discretionary power. While they are
figureheads, in practice they exert considerable influence and are often
involved in the political and economic affairs of their states. The Sultan of
Johor, in particular, was an active businessman, who had found ways to
include himself into a number of deals worth billions of dollars. 11
Following the early success of a project in Danga Bay, 12 Country
Garden committed to a second large real estate development in Johor.
According to media reports, Sultan of Johor Ibrahim Ismail invited them to
embark on the project. Under the Iskandar masterplan prepared by the
Iskandar Regional Development Authority (IRDA), the southeastern side
of the state had become the focus of new development and investment. 13
Desiring more evenly balanced development, the Sultan convinced
investors to develop a marine site on the neglected southwestern side. A
project director later praised the Sultan as “very visionary…he is the one
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who urged investors to come in.”14 A professor of hydrology at UTM

(Universiti Teknologi Malaysia), Dr. Maketab Mohamad, described the
Sultan as “the key player that made this project happen.” 15 He said that
there was an unwritten rule that all major decisions require the tacit
approval of the Sultan—part of an invisible yet inexorable power structure.
The Sultan took a sizable personal stake in the US $121 billion project 16
through a combination of direct ownership and holdings by a close
associate. He presumably tried to shortcut the early approvals process in
order to move the project forward. Country Garden’s regional president for
Malaysia, Kayson Yuen, has stated that the company studied the project
for more than a year before they decided to invest. 17 If true, this would
place conception at some point in 2012.

Figure 3. Sultan of Johor (official royal portrait)

Rationale for siting Forest City in Johor

The southern state of Johor, with its proximity to Singapore, was
seen as the ideal site for Country Garden’s first large-scale Malaysian
venture. While Singapore is an island, it is far from isolated. Economic and
labor linkages between Johor and Singapore bring more than 200,000
people across the causeway every day. Workers live in Johor (where
housing prices are much lower) and commute to work in Singapore.
Dramatically lower costs in Johor justify for many what can be a two-hour
crossing due to immigration and security checks. Through its economic
dynamism, Singapore has created increasing demand for housing near its
borders. 18 In many ways its “hinterland” is Malaysia, where many
industries have moved and supplies are sourced. A growing number of

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Singaporean firms, moreover, have moved their back offices to Johor in

an effort to cut costs. Interest in developing more housing in Johor is
further strengthened by skyrocketing real estate prices in Singapore.
Country Garden’s interest in Johor is motivated by an effort to seek
returns overseas amid a slowing domestic property market in China, and
higher barriers to investing elsewhere. Lower prices and fewer market
restrictions than in places like Hong Kong have made the region attractive.
While Singapore itself has strong appeal, it is an expensive, mature
market, with relatively fewer compelling development opportunities. 19
Compared to other Asian nations, moreover, Malaysia has been politically
stable and has maintained relatively good relations with China. In light of
disputes over islands in the South China Sea, Chinese investments in
Vietnam and the Philippines carried political risks. 20 Other potential sites
for investment, such as Thailand, restrict foreign ownership of property.
Cultural similarities and the large number of Chinese-speaking Malaysians
no doubt further enhance Johor’s appeal. 21
A large and established following in China gave Country Garden
confidence that it could generate demand in China for new Malaysian
homes. Country Garden Holdings sales and marketing general manager
Nicholas Hum epitomizes this optimism, claiming that “we have one million
owners in China, and it's like a fan club. Wherever we go, there are just
buyers that buy without any questions." 22 Forest City’s planned
educational partnerships, including agreements with international boarding
schools, were seen as a powerful enticement: "A lot of them are
concerned about their kids. They plan quite far ahead," said Hum.
Country Garden expectations were likely buoyed by the initial
success of its first Malaysian venture at Danga Bay, also along the Straits
of Johor. The company released some 9,000 units simultaneously, and
some 6,000 of them were reportedly taken up in a short period—as little
as a day after hitting the market. 23 Still more remarkable, those sales
preceded completion of the units by several years.
Danga Bay encountered relatively little opposition from
environmentalists. This reflected the fact that although the project
involved some land reclamation, most of it was built on existing land.

Criticism and broader context

Some commentators have questioned the need for land
reclamation, when Johor clearly has no shortage of open development
sites. An executive at a rival Chinese firm, Dr. Jeffrey Yee, explains that in
order to attract high-value international buyers, developments need to be
by the sea. “You can’t just put up a cluster of towers in the middle of JB
[Johor Bahru] and expect to attract that much attention,” 24 he noted.

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Presumably, reclaiming new land allows the developer to maximize the

number of units near the water and increase overall development value.
Country Garden sees similarities between Johor and Shenzhen in
China, where it has undertaken several large developments. 25 Both areas
are positioned next to much wealthier, more developed neighbors that are
global hubs of trade and finance. By leveraging close linkages with Hong
Kong, Shenzhen emerged as a manufacturing powerhouse and a
destination in its own right. While the analogy is imperfect—Singapore and
Malaysia are separate countries, whereas Hong Kong is a special region
of China—Country Garden was optimistic that Johor could benefit from its
ties to Singapore in the same way that Shenzhen benefitted from its ties to
Hong Kong. Increasing costs in Singapore had already begun to persuade
factories and offices to relocate in cheaper areas across the border, as
had occurred in Hong Kong. Well before the inception of Forest City, other
large development projects, “mushrooming along Malaysia’s shoreline
facing Singapore,” 26 had invited the comparison.

Accounting of stakeholders
Fishermen living in small villages, or in Malay, were among those
most directly affected by the project. Kampong Pok and Kampong Pendas
are two such villages that are close to Forest City and are dependent on
the sea. Fishermen living there were the first to become aware of the
project, and also among the first to express their opposition. They feared
for their livelihoods, as extensive land reclamation threatened to reduce
and pollute their fishing grounds. Country Garden was eventually
compelled to establish a compensation fund disbursing RM 104 million for
the fishermen, administered through the Johor Fisherman’s association. 27
At the same time, however, the developer argued that the area’s
fishermen had no future at sea, and encouraged them to seek more
“modern employment.”28
Opposition politicians, particularly those in districts near Forest City,
emerged as outspoken opponents of the project. Individuals such as Cheo
Yee How, an environment spokesman for DAP (Democratic Action Party),
drew attention to the risks to the seagrass and mangroves. 29 Other DAP
members, such as Boo Cheng Hau and Lim Kit Siang, also criticized the
project and posed many questions to the developer. 30 Boo Cheng Hau
asked how the project began without an EIA, and argued that the
community had the right to know whether large-scale land reclamation
would cause adverse environmental impacts. 31 In a published review of
the project, he claimed that project benefits would be distributed
unequally, and expressed his concern for the indigenous Orang Seletar
community. 32 Lim Kit Siang, meanwhile, sought to determine the project’s
impacts on fishermen. 33

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Within the Singaporean government, the Department of

Environment and the Foreign Ministry were the most closely involved in
monitoring the project, but other agencies and boards were also
involved. 34 A few months after reclamation commenced, the Foreign
Ministry sent two diplomatic notes requesting more information and asking
for an EIA. 35 A previous dispute over land reclamation in 2003 no doubt
influenced Singapore’s behavior. 36 The Environment Ministry was
principally concerned about possible impacts on the hydrology of the
Straits. 37 Singapore emphasized the need for Malaysia to comply with
international law. At one point, both prime ministers were engaged in
discussion of the project. 38
Country Garden, and more particularly its Malaysian subsidiary
CGPV, was Forest City’s developer. Successful development of large
townships in Southern China propelled Country Garden to the top ranks of
Chinese developers. 39 The Danga Bay project was their first foreign
venture and Forest City would be their flagship project. 40 CGPV was
created as a joint venture between Country Garden Holdings Ltd, the
Chinese developer, and Esplanade Danga 88, described as a
representing the Johor state investment arm, but in reality a holding
company for the share of the project held by the Sultan. 41 It is headed by
Datuk Othman Yusof, who would frequently act as its spokesman and
headquartered at Danga Bay. 42
A number of environmentalists and environmental NGOs protested
against the project. 43 They were concerned that a priceless natural
heritage—in the form of mangroves and Malaysia’s largest seagrass
bed—was under direct threat from the development. They drew attention
to the lack of a required EIA, and to the failure to consult with either
environmentalists or villagers during the design process. 44

Research resources and methodology

A central component of the research for this thesis involved
conducting eighteen open-ended interviews with a range of stakeholders
involved in the Forest City project. These included fishermen from villages
near the reclamation site, planning staff at IRDA, representatives from
Country Garden, Johor environmentalists, marine researchers, rival
developers, and Johor politicians. An open-ended, unstructured format
facilitated conversations with each interviewee, highlighting their concerns
and determining their knowledge of what had happened.
Most interviews took place during fieldwork in Johor and Singapore
between early July and late August 2015. Interview durations ranged from
about fifteen minutes to more than two hours. Virtually all conversations
were conducted on-site in locations convenient to the subjects. In a
handful of cases involving fishermen in the village of Kampong Pendas,

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Dr. Serina Rahman served as a translator. Interviews were recorded if the

subjects gave verbal consent. In two cases, subjects were unable to be
interviewed in person and instead answered questions by email.
A subsequent set of interviews was conducted during a return visit
in January 2016. During this time the author attended a global press
conference in Singapore, during which Country Garden officially launched
the project. Another researcher fluent in Mandarin, MIT Urban Planning
student Libbie Cohen, traveled to Shanghai and Singapore during fall
2015 to conduct two additional interviews, both with Sasaki Principal
Michael Grove. A table of everyone interviewed is included in appendix A.
Requests to speak with the Sultan of Johor or a member of his
office were not answered. Efforts were also made to interview officials in
the Singaporean government, particularly its foreign ministry and
department of environment. These conversations were perfunctory and
yielded no new information. Similarly, requests to interview members of
the Johor department of the environment, the Johor State Economic
Planning committee, and members of the local council directly involved in
approving the Forest City project either went unanswered or were turned
down. The absence of interview information from any of those government
agencies in Johor and Singapore, as well as from the Sultan of Johor,
leaves gaps in this study. However, a review of articles, transcripts, and
newspaper accounts has been used to fill many of these gaps.
The Detailed Environmental Impact Assessment that was ultimately
prepared for Forest City served as a chief source for many of the technical
details about the project. It includes plans, environmental studies,
descriptions of mitigation measures, and social impact estimates. It also
includes summaries of key focus-group discussions and responses to
formal questions put by officials that in some cases are the only
authoritative indication of Country Garden’s viewpoint.
A variety of sources were used to uncover investment and
economic figures for Johor and Iskandar Malaysia. A number of planning
documents, including those prepared by both state and federal agencies,
also proved valuable. These include IRDA’s shoreline management
plan, 45 the Iskandar Malaysia Comprehensive development plan, 46 and
reports by Khazanah Nasional (the Malaysian federal investment fund), 47
among others. Finally, promotional materials provided by Country Garden
itself—either online, through brochures available at its sales gallery or
materials given to attendees of its global press conference in Singapore—
yielded important information about the developer. 48
More than 150 reports were found through an exhaustive media
search encompassing virtually every web-published report about the
project from mainstream news outlets in English. Additionally, a smaller
number of media reports were gathered from Malay and Chinese
(Mandarin) sources that were subsequently translated. Supplementing
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these articles were newscasts and videos in multiple languages, including

drone footage of the project recorded by activists, some of them posted to
YouTube. Articles and media reports originally published in Mandarin were
translated by Libbie Cohn. Additionally, a number of Malay language
(Bahasa Malayu) articles were machine-translated and subsequently
reviewed for correctness by various native Malay speakers.

Figure 4. Rendering of Forest City

Source: Country Garden promotional brochure distributed at Forest City global
press conference in Jan 2016.

Global megaprojects: characteristics and

examples
Summary of key attributes of urban megaprojects:
• Large investment, often in the billions of USD
• Project capital is sourced globally or nationally
• They have strong linkages to global networks
• They have a construction lifespan measured over decades
• Their design, planning and construction often draw on an
international workforce of professionals, consultants, and
laborers
• They are seen to bypass traditional systems of government
• Demand forecasts, cost estimates, and projected benefits
are characterized by high levels of uncertainty

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• Secondary benefits are expected for society at large, and not

just the project proponent
• It is argued that they reflect new systems of governance
which prioritize elites over locally affected populations
• Regional and local plans often do not direct investment in
megaprojects
• Actors outside the planning and development realm often
have a strong influence on the projects
• The new paradigm of megaproject development strives to
minimize popular resistance and avoid displacement
• Projects pose serious concerns for urban sustainability,
whether in the form of sprawl or damage to the natural
environment
• They seek to position cities on a global stage to enhance the
perceived competitiveness of a region
• Despite their ostensible break with megaprojects of the past,
new megaprojects still adopt a top-down planning approach

County Garden’s Forest City project meets or surpasses all the

commonly accepted attributes of urban megaprojects. It is intended to
span more than 14 square kilometers, involve a massive 20-year
reclamation effort and investment totaling US $45 billion. 49 At its peak it
will employ more than 5,000 workers, require the construction of new
roads, power plants and a vast network of supporting infrastructure.
Country Garden suggests they will construct 300,000 50 units of housing,
accommodating hundreds of thousands of people and creating tens of
thousands of jobs. While the project is headed by a private Chinese
developer, the Johor State government is invested in Forest City through a
stake held by KPRJ (Kumpulan Prasarana Rakyat Johor), its public
investments arm. Thus, the project is something of a public-private
partnership. The project has enjoyed significant government support and
is now integrated into the formal regional development strategy. 51
Aside from its large scale, the most distinctive characteristic of
Forest City is its reliance on land reclamation. There are few projects that
compare with the proposed 14-square-kilometer reclamation, spread over
four islands in the Straits of Johor. Land reclamation is expensive, and
may be difficult to justify when there is ample existing land available. The
most prominent analogues are in the Persian Gulf, including the famous
Palm Jebel Ali and its Qatari response, The Pearl in Doha. These iconic
projects help forge a national identity while enhancing the prestige of the
cities and states in which they are situated. Moreover, they exemplify the
international urban enclaves discussed in the globalization literature. Yet
these projects also have significant environmental and social impacts. The

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Palm Jebel Ali disrupted local hydrology and threatened marine life. The
Pearl, meanwhile, was implicated in a number of human rights abuses
involving its migrant workforce. In both cases, these impacts have a
bearing on Forest City.
As Country Garden embarks on the Forest City project in Johor, it
carries with it many of the lessons it learned from over 20 years of
designing, building and managing townships across China. Design
attitudes, many of which reflect the “Chinese dream,” will inevitably shape
the form and execution of Forest City. Yet Country Garden’s Malaysian
flagship is also something fundamentally different. The company is not
simply building tracts of housing or developing a coastal resort; it is
attempting create a new city altogether, down to the very land on which it
sits. Forest City presents Country Garden with a unique opportunity—and
at the same time, a tremendous responsibility.

Analysis of Forest City

Non-compliance and co-optation
What emerges from the literature on megaprojects and many
practical examples is a broad theme of noncompliance and co-optation.
By virtue of their scale and exceptionality, megaprojects often exist
outside the realm of established regulations and planning structures. Their
proponents, who are frequently powerful actors external to planning and
government, effectively co-opt the development system to pursue their
narrow interests. For such actors, disregard for local populations often
mirrors their disregard for plans and regulations; there is very little, if any,
engagement or consultation with local communities. The Forest City case
provides a rich illustration of these processes at work.

Lack of compliance with plans

Based on a review of the relevant academic literature, experience
with global urban megaprojects has demonstrated that regional and
national planning efforts have minimal influence on the specific path of
investment and urban development. Urban megaprojects often lie outside
the formal planning system. Their scale, magnitude of investment, or
strategic purpose enables them to be considered exceptional. Such
projects are generally not included in urban or regional plans, or are only
incorporated retroactively. They are implemented with provisional
measures that can sidestep statutory or regulatory requirements. 52
The case of Forest City is remarkably consistent with these
patterns. The project was not described in any national or regional plans
for Johor. In fact, the development directly contradicted existing planning
priorities for the site; it was initially recommended for protection as an

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environmentally sensitive area. 53 National regulations, in particular,

suggest the scale of reclamation would be illegal without specific
approvals, which were generally not granted before reclamation
commenced. Even after the project began, it was grossly out of
compliance with environmental regulations surrounding an environmental
impact assessment. The combination of these factors paints a convincing
picture of “exceptionality,” 54 in which plans, regulations, and requirements
were openly disregarded.

Existing plans and regulations

A 2011 IRDA shoreline management plan for Iskandar Malaysia
indicates strong environmental priorities that are entirely incompatible with
the Forest City development. The area includes the Merambong Island, a
small uninhabited stretch of land near the international border, and the
seagrass beds of Merambong and Tanjung Adang shoals—in short, nearly
the entire area that would be occupied by Forest City. The area was
specifically designated for management in order to “protect marine flora
and fauna, especially [the] seagrass bed.” 55 The only proposed
development in this management plan was a small research platform
intended to facilitate research on dugongs and monitoring of the seagrass
beds.
The location was further classified as an environmentally sensitive
area “rank one,” which “disallows any development except for low-impact
nature tourism, research, and education.” 56 An IRDA land use blueprint
echoes the environmental importance of the seagrass beds, calling them
“core conservation areas” in which “no further development is allowed,
except for eco-tourism, research, and education.” 57 These appear to have
been planning designations, lacking judicial and executive authority, but
they nonetheless clearly signal IRDA’s intentions for the region.
Furthermore, the plans indicate a formal initiative to establish the
site as a “marine protected area.”58 At the time (2011), the site lacked
formal environmental protection along the lines of nearby areas, but was
noted for its environmental value. The blueprint recognizes the marine
diversity of the site, its importance as a feeding ground for various marine
species, and its role as a critical landing ground for migratory birds. The
port of Tanjung Pelepas is acknowledged as the principal threat in the
area. IRDA intended to cooperate with the Johor Port Authority and
Marine Department (Jabatan Laut Malaysia)—the agencies with direct
jurisdiction over the site—to administratively declare Merambong island
and the seagrass beds to be a protected area. It outlined a detailed plan to
staff the new site, facilitate research, and establish a low-impact tourist
industry involving local residents. 59

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The comprehensive plan for the development of Iskandar Malaysia

(CDP) includes the land around the future Forest City site as part of its
“flagship C,” with primarily industrial land uses. Among the list of
prescribed economic activities—including manufacturing, logistics,
warehousing, and entrepot trade—residential developments are notably
absent. 60 The national physical plan demands that “sensitive coastal
ecosystems shall be protected and used in a sustainable manner.” Listed
among the “areas that are environmentally sensitive” are the seagrass
beds near Merambong shoal. They are described as “a nursery and
feeding ground, permanent habitat and shelters for fish.” The plan
specifically underscores their role as feeding areas for dugongs. 61
The South Johor CDP also places emphasis on protections for
existing Ramsar sites of Sungai Pulai and Tanjung Piai, which are within a
few kilometers of the Forest City site. The Ramsar convention of 1971,
known as the convention on wetlands, establishes a framework for
international cooperation on the convention and management of wetlands.
Areas designated as Ramsar sites are “wetlands of international
importance,” critical to conserving biological diversity. Underscoring the
importance of this designation, the South Johor CDP identifies a need for
“control measures...to protect these special areas…namely those around
the Port of Tanjung Pelepas”62—in other words, the future site of Forest
City.
The Malaysian national physical plan (NPP), a federal document,
states that any reclamation works larger than 20 hectares must be
specifically approved unless already outlined in the plan. Furthermore,
NPP generally prohibits coastal reclamation unless for the purposes of
security or port development. 63 As the Forest City project was originally
estimated at 2,000 hectares on entirely reclaimed land, it clearly violated
all these provisions. Another set of environmental laws established
requirements for environmental impact assessments (EIAs). The 1987
Malaysian Environmental Quality Order, in combination with the 1974
Environmental Quality Act, mandated a DEIA (detailed EIA) for all coastal
reclamation projects greater than 50 ha. Moreover, they require an EIA for
the construction of new townships, regardless of size, and for all coastal
resort facilities or hotels with more than 80 rooms. 64 Again, the Forest City
project fails to comply with all these measures.

Initial Actions in Johor

Given that Forest City blatantly contradicted so many plans and
regulations at multiple levels, it remains puzzling how the project managed
to begin in the first place. Over the course of 2013, Country Garden
Holdings Ltd. and a Malaysian corporate entity, Esplanade Danga 88,
entered into a joint venture to create Country Garden Pacificview (CGPV),

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the entity undertaking the Forest City project. On November 8, 2013, five
large parcels of marine area were “alienated” to the company, totaling
4,887 acres, or 1,997.7 hectares. All of the parcels were located in the
waters off the Straights of Johor, adjacent the Tuas Second Link crossing
to Singapore and the Port of Tanjung Pelepas. The area encompassed
the seagrass bed at Merambong shoal, the largest in peninsular Malaysia,
as well as a nearby bed at Tanjung Adang.
While the DEIA claims that the “land” lots for the project were
contained within mukim Tanjung Kupang, a district of Johor, it is unclear
which authorities were required to give their permission for the project.
Under Malaysia’s national land code, all foreshore and seabed are
considered state lands, which in this case would be administered by the
Johor government. 65 Indeed, it was the Johor government that initially
approved the project. IRDA planning documents, however, suggest that
the project site fell under control of the Johor Ports Authority (JPA) and the
National Marine Department, which are both federal bodies. The entire
Forest City project fell within the border of the Port of Tanjung Pelepas
and directly conflicted with approved expansion plans, according to
documents provided as part of the DEIA. 66 Yet there is no mention either
in the project’s DEIA or in media reports of CGPV having received
approval from the JPA or national marine department.

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Figure 5. Parcels "alienated" to Forest City 67

The lack of communication between CGPV and federal agencies is

evident in the complete absence of port directives regarding the
reclamation. Despite the proximity of the Forest City reclamation works to
the Port of Tanjung Pelepas, no port “circulars” were issued for the
entirety of 2014. Reclamation elsewhere in Johor, much of it posing much
less risk to navigation, was duly announced throughout the year. 68 A
circular issued in mid-January 2014, for example, when reclamation was
claimed to have begun, referred to reconstruction of a jetty near the port.
Despite its clear relevance to marine safety and navigation, no reference
to the Forest City project appears until October 2015, when a “working
area” was established for “reclamation activities in the Tanjung Pelepas
Port limit, Johor.” 69
A dubious chain of events surrounds the project’s initial approvals
and interaction with the Johor Department of Environment (DOE). On
January 13, 2014, CGPV received a letter from the Johor DOE informing
them that the first phase of reclamation, encompassing 49.3 hectares,
could proceed, since it fell under the 50-hectare threshold established
under Malaysian environmental regulations. 70 CGPV then submitted a
PAT (Penilaian Awal Tapak), known as a “preliminary site assessment,”
for its first phase of the project. Considered a “preliminary screening” for
new projects that ensures “compatibility…with surrounding land use and
land use planning,” the PAT is required before a formal EIA report can be
submitted. Despite later claims by CGPV that the project—or at least its
first phase—did not require an EIA, submitting a PAT suggests that the
company did recognize its project was among the list of “prescribed
activities” for which an EIA is necessary. As one comparative study on EIA
procedures notes, “the reason behind conducting a PAT is to ensure that
the proposed site for the EIA project are [sic] being assessed and
screened before the submission of the EIA report.” 71 The contradiction
leaves many open questions.
According to reports of other projects in Johor, DOE approval
indicates that the project was deemed compatible with the gazetted
structure and local plans, land use, buffer zones, and other general
requirements. 72 Since a host of evidence suggests quite the opposite, the
result is striking. It is difficult to believe that the Johor DOE—an agency
tasked with environmental protection—would be ignorant of the presence
of seagrass in the proposed reclamation area. 73 This suggests that they
either willfully ignored the environmental implications of the proposed
reclamation, or were otherwise swayed. It is also difficult to believe that
they were unaware of the overall scale of the project and therefore
allowed the first stage to proceed without an EIA. Even in the unlikely
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scenario that they knew nothing of CGPV’s ultimate ambitions, land

records would have indicated that the project spanned a vastly greater
area than 50 ha. 74 Hana Badriah, a planner at IRDA who previously
worked at the Johor DOE, noted from her experience that “the whole plan
for a development needed to be submitted before it could begin.” 75 A
project would be rejected if its proponent presented only a portion or first
phase. Badriah remains puzzled how the project gained approval without
a DEIA, especially since both the state and federal DOE have power to
require an EIA for reclamation independent of the statutory threshold. “It’s
funny that the state wouldn’t ask,” she noted.
By its own accounting, CGPV began reclamation work on January
22, 2014. Given the time needed to arrange the ships, earth-moving
equipment, and other physical infrastructure necessary for reclamation,
CGPV must have been all but certain of the approval and massed its
resources in anticipation. Yet accounts from local residents contradict
even this compressed timeline. According to Serina Rahman, a resident of
the Tanjung Kupang area nearest the Forest City site who runs an
environmental NGO, reclamation actually began on January 1, 2014, well
before any dates given in the DEIA. She further asserted that the area had
been surveyed and marked out even earlier, at the end of 2013, 76 a claim
supported by Kartine Majid of Johor developer UEM Sunrise. 77 No locals
had been consulted or even informed about the project prior to the start of
reclamation. 78
CGPV began work by constructing a causeway from the mainland
to main body of their nascent island. Its path bisected the Merambong
shoal seagrass bed, smothering much of the bed and restricting water
circulation vital to its ecology. Rahman, who later met with Country
Garden representatives, related that they were ostensibly ignorant of
seagrass ecology and the damage done by reclamation. She noted that
“they were genuinely amazed by what we were telling them [about the
seagrass]” and thought they “actually want to do something to make up for
how much they have screwed up already.” She attempted to assign blame
to “local parties,” who were insistent on “pushing this [Forest City project]
through.” 79

Confusion, CGPV response

Among Johor officials, there was a great deal of confusion and
misinformation surrounding the Forest City project. By the beginning of
June 2014, the project had attracted substantial attention, and authorities
were now under heavy scrutiny. Responding to inquiries from the now-
defunct Malaysian Insider, Johor State health and environment committee
chairman Ayub Rahmat said on June 23 he thought it unlikely that Forest
City would have no environmental impact assessment: “It is improbable

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that there is no EIA report if it is indeed required.” He went on to argue

that “whether it’s a big or small company doing the project, I’m sure they
know the law, so let’s not politicize the issue until we find out facts.”80 Yet
days later, Rahmat announced that CGPV would be expected to prepare a
DEIA report. He added that “given the large area involved the DEIA is
crucial as it allows a better assessment of the project’s potential
environmental impact.” 81
Earlier in the week, Johor DOE director, Moktar Abdul Majid, had
defended the lack of a project EIA, contending that “as the area reclaimed
is not more than 50 acres [hectares], it does not require the EIA report.” 82
Yet again, shortly afterwards, the Johor Mentri Besar (chief minister)
Khaled Nordin claimed in the state assembly that while the project was
under 50 hectares and would not require a detailed EIA, it would require a
preliminary EIA: “in view that the project is inclusive of a hotel equipped
with 80 rooms, the developer is required to prepare a preliminary EIA
report as stipulated under the Environmental Quality Act 1974.”83 Why this
other provision had not been acted upon earlier to mandate an EIA (either
preliminary or detailed) remains unclear. In any case, the Forest City DEIA
claims that the DOE Johor “issued a letter requesting for a Detailed EIA
for the proposed reclamation,” on June 6, well before any of the above
remarks. 84
A closer look at the threshold of 50 hectares reveals it to be a flimsy
rationale for failing to complete an EIA. In addition to Johor officials, CGPV
also makes wide use of the argument throughout its responses to public
questions and focus group discussions with nearby stakeholders. When
asked variations on “how was the reclamation done before the approval of
the DEIA,” CGPV reliably responded that it had “obtained clearance for
the reclamation for its pilot project…measuring 49.3 ha. Any reclamation
project less than 50 ha does not need a DEIA study.” CGPV attributed the
later change in course to “developments after the initial works.” 85
While the 50 ha threshold is legitimate, the argument is specious; it
implies that any developer intent on reclaiming more than 50 ha could skirt
the rules by subdividing the project and obtaining separate approvals for
each phase. Environmental policy researcher Chung Yi Fun weighed in on
this issue, claiming “if you reclaim in parcels of 49 hectares to circumvent
the DEIA, then it defeats the purpose of having a DEIA at all.” 86 The only
sensible interpretation demands that EIA requirements apply to a project
in its entirety and not cherry-picked sections. Furthermore, as chief
minister Khaled Nordin alluded to in the “hotel with 80 rooms” justification,
a number of other provisions apply to the project that mandate an EIA
irrespective of the amount of reclamation. New townships—a category for
which Forest City clearly qualifies—and new coastal resort developments
also mandate EIAs. 87

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CGPV’s confronted a wide range of pointed questions regarding its

lack of compliance with plans and regulations. The clearest articulation of
CGPV’s response is found in its published answers to public questions
and stakeholder discussions. Revealingly, in almost every case, CGPV
declines to engage with the particulars of compliance, noting instead that
the project obtained “zoning approval” from the Johor government. In
particular, CGPV makes repeated reference to a letter from UPEN Johor
(the Johor State Economic Planning Committee) received on September
3, 2014, which notes that state planners have approved the project and
determined that the project did not need to be referred to the national
physical planning committee. 88
The implication, presumably, is that such approval is sufficient to
establish Forest City’s legality. Yet the letter was issued nine months after
reclamation commenced—a chronological sticking point that remains
unaddressed. CGPV goes on to say that Forest City will be incorporated
into the relevant plans in the “near future.” They also claim that “the
project is approved because it will bring economy [sic] growth and benefits
to the communities, state and country.” 89

Outside actors: role of the Sultan

Sultan of Johor Ismail Ibrahim played the defining role in bringing
about the Forest City project. The Johor monarch, also known by his royal
title “Tuanku,” invited Country Garden to invest at an early stage, and then
himself took a large financial interest in the project. There is ample
evidence to suggest that Forest City is indeed “the Sultan’s project.” 90
Ismail Ibrahim’s central involvement invokes another theme in the
megaprojects literature: the tendency of actors outside the formal
structures of planning and development to co-opt strategies and reorient
objectives to suit their own interests. 91 Certain entrepreneurial actors, by
virtue of their standing or influence, successfully advocate for large-scale
interventions that are incompatible with existing planning priorities
conceived through more democratic or inclusive means.

Background on Malay sultans and the Sultan of Johor

Hereditary Malay Sultans rule nine of Malaysia's 13 states. Each
rotates through a five-year term as Agong, the king of the Malaysian
federation. As noted, Malay sultans act as constitutional monarchs and
stewards of Islam. At the federal level, the Prime Minister and his cabinet
make executive decisions. Chief Ministers, or menteris besar in Malay,
hold executive power at the state level. 92
Until 1983, Sultans wielded considerably more power, enjoying
legal immunity and a royal veto over legislation. That year, the
administration of Mahathir Mohamad brought in sweeping constitutional
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changes intended to curb their influence. Parliament and state assemblies

were empowered to overrule the royal veto following a prescribed waiting
period. Subsequently, in 1993, royal families were stripped of legal
immunity following allegations of assaults on citizens in Johor, including by
the current Sultan’s father and younger brother. 93 Mahathir justified the
changes on the grounds that the monarchs could not be trusted to act on
the advice of elected officials, as in the UK. He also reflected on
Malaysia’s colonial history, where “rulers could be so easily persuaded to
make wrong decisions.” 94
In theory, therefore, Sultans in Malaysia are now closer to
figureheads. In practice, however, they remain immensely influential in
both the economic and political affairs of their states. Chief Ministers, for
example, are still appointed by the Sultan in a number of states, including
Johor. 95
Born in 1958, the current Sultan of Johor, Ismail Iskandar, enjoyed
a highly international upbringing. He is the son of a Malay father, Johor
Sultan Mahmud Iskandar, and a British mother, Josephine Trevorrow, who
adopted an Islamic name after marriage. The two met while Mahmud was
studying in the UK. Ismail trained as a military officer and studied
diplomacy and international relations at Tufts University. He reportedly
completed coursework related to the International Laws of the Seas, later
to prove relevant in disputes with Singapore over reclamation. 96
After ascending to the crown on the death of his father in 2010,
Ibrahim has been intensely active in the business affairs of the state. He
made several notable investments and acquisitions in past years,
including a 20 percent stake in Berjaya Times Square (reportedly worth
RM 250 million), a shopping center in Kuala Lumpur, and a majority stake
in REDtone international, a Malaysian telecom provider, among many
others. Serina Rahaman, a Johor resident, posits that the Sultan pursues
such deals, especially opportunities in Johor, in an effort to edge out
“federal level cronies,” who might otherwise dominate local players. 97 As
of 2015, he had reportedly amassed a personal fortune exceeding $1
billion. 98 He lives a high-profile lifestyle with the full trappings of wealth
and royalty, including several palaces in Johor, a customized Mack
“palace truck,” and a Boeing 737. 99 The Sultan has in the past faced
allegations of criminal misconduct, including several assaults in nightclubs
and even a shooting, all of which were dismissed because of immunity
rules then in place. 100
In spite of the fact that he already exerts great influence in Johor,
the Sultan has repeatedly sought to consolidate and increase his power. A
bill proposed in 2014 to address affordable housing issues would have
given the Sultan uncontested power to appoint members of the new
housing board, set their pay, and even dissolve the board. 101 The law was
eventually modified to shift these powers to the state government after it
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encountered heavy resistance. In December 2015, the Sultan unilaterally

declared a ban on electronic (or “vape”) smoking devices. The sudden
decree immediately raised issues of due process. Legal experts
contended that “the Sultan as a constitutional monarch cannot just issue a
decree on vapes.” 102 Most recently, the Sultan has called for the federal
government to repeal earlier amendments that limited monarch’s powers.
The Johor ruler claimed “it is not proper to limit or abolish the power of the
King or Sultan in examining and giving their royal assent to laws.” 103
Perceived weakness in the federal government, in the throes of an
ongoing financial scandal, may be encouraging the Sultan’s ambitions.

Deal with Guangzhou R&F

Of all the Sultan’s ventures, his investments in Johor property have
proved most controversial. One deal in particular with Chinese developer
Guangzhou R&F sheds light on his dealings with Country Garden. In
December 2013, the Sultan reportedly made RM 4.5 billion through the
sale of 116 acres of prime land flanking the causeway in Tanjung Puteri,
at the heart of Johor Bahru. 104 The area had formerly been owned by the
state government and was acquired by the Sultan for roughly RM 200
million, an order of magnitude less than his subsequent sale to
Guangzhou R&F. Facing public and press scrutiny over the deal, the
Sultan explained his actions in an interview:

For example, the Princess Cove project [by Guangzhou

R&F] in Tanjung Puteri. Some people wanted the land for
free to be injected to some major public listed companies.
There were two people who wanted the land…An
independent evaluation was done on Tanjung Puteri and a
price was offered based on the market value. I paid the
government above its market value [for the land]. I rounded
up the figure offered and made the government an offer they
could not resist…I did not take the land free of charge. I paid
extra for the land because I want the state government to
make money, which will be channeled back to the people. 105

In what he termed a “transparent dealing,” the Sultan claimed he

had essentially paid double for the land, which was assessed by the
government at RM 100 million. He then entered into a joint venture with
the developer Guangzhou R&F, somehow acquiring a 30 percent stake in
the project. The Sultan then explained how he managed the RM 4.5 billion
deal:

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I have a 30 per cent share with the joint venture company. I

foresee a RM 100 billion gross development value (GDV).
Under the normal industrial norms, you will make at least,
even in the worst scenario, between 20 and 25 per cent in
profits. So I did basic arithmetic. What is 30 per cent of 20?
That is six billion. That is the profit at the end of the day in 10
years by looking at the GDV. But, do I want to wait 10 years?
Would I know when the market will weaken?...I am not
willing to take that risk. I asked for my profits in advance and
in return, I offered them a RM 1.5 billion discount. That is
how RM 4.5 billion came up. I did not sell but I took profit in
advance…I didn’t lobby anybody. It was a transparent deal
that will see Johor progress in the future. 106

The Sultan did not elaborate on the specifics of the joint venture or
how much he had invested in order to acquire his 30 percent stake.
Assuming as given the Sultans 20 percent profit figures, this suggests that
investment in the project would have totaled RM 80 billion, placing the
Sultan’s share of investment at RM 24 billion. It is evident the Sultan did
not invest this amount, given that it would exceed his net worth several
times over. More likely, he was granted his stake in the development for
facilitating the land acquisition, or for other unexplained reasons. His
math, moreover, departs from conventional financial models. Any
reasonable discount rate for a speculative project like that of Guangzhou
R&F would yield a vastly lower value for profits in the present term.
The Sultan’s deal with Guangzhou R&F came amidst a dramatic
growth in large-scale real estate projects launched by Chinese
developers. Local Malaysian developers worried that the market could
become rapidly oversupplied. 107 The government in 2013 had already
implemented “cooling down measures” intended to stem rising property
prices and speculative buying. Malaysian developers were responding by
scaling back new launches or shifting to landed properties. 108 Some also
questioned whether the Sultan’s “sale of prime state land to China” was
“politically insensitive.” 109 Both the ruling and opposition parties took issue
with the sale of land to foreigners. 110
Yet there was little vocal opposition to the Sultan’s deal. The Sultan
is held in great esteem, even awe, by Johor citizens. Malay adat, referring
to customary practices and tradition linked to Islam, in general prohibits
opposing the Sultan. As a traditional Malay monarch, publically criticizing
him is “seen as a social taboo.” An unnamed Johor businessman
interviewed by Malaysiakini (an independent media outlet) confirmed that
“yes, there is definitely a fear factor.” 111 Concerns over repercussions are
well grounded; in the past, critical bloggers have been threatened with
colonial era sedition charges. Off the record, however, Johoreans
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expressed deep dissatisfaction with the Sultan’s business activities. A

Johor lawyer quoted by Malaysiakini: “With all due respect, he (the Sultan)
shouldn’t be involved in business. This is the first Sultan known to
Malaysians to sell land to China. And it is prime city land. It is
unprecedented.”
The same lawyer further argued that royalty should be “above
politics.” Given that the Johor Sultan receives a generous RM 27,000-a
month allowance 112 from the government, “they don’t need to be in
business.” His influence and special role suggest that it would be difficult,
if not impossible, to compete with the Sultan. The Sultan, for his part,
argued that since he did not bid on projects, he was not in competition
with others: “I am not like any ordinary businessman…I buy shares. I sell
shares. I study about shares.” 113

The Sultan’s role in Forest City

Given his history of business dealings and record of close
involvement in Johor affairs, it is unsurprising that the Sultan initiated the
Forest City project. As he explains:

Forest City, which will be built in southwest of Johor, was my

idea. I brought the Forest City investors in. The developers
took into consideration my ideas. The investors visited the
proposed site and established that it was strategically
located. They have confidence in the government and me,
and they are also comfortable here in Johor, which is
peaceful, united, and strategically located. 114

The Sultan went on to claim that the project would generate income
for the government through fees and quit rents. People in Johor would
benefit from “spill-over effects,” including retail opportunities and
“upgrading our transportation system.” He further claimed it would create
250,000 job opportunities for residents of Johor. The Sultan dismissed
concerns over Chinese investment, asking “what is wrong if developers
from China what to invest in Johor?...we have an open-door policy; every
reliable investor is welcome to invest in Johor.” 115 He added “if there are
any Americans, Britons, Australians…who would put money in Johor, they
are welcome, but where are they? . . .The Chinese have the confidence
and foresight to believe that their money is well spent [here].”116
According to media reports, the Sultan had been concerned that
development and investment had been spread unevenly across the
Iskandar Malaysia region. Othman Yusof, the executive director of CGPV,
later commented that “this area was spotted by our sultan, who in fact
wanted to see balanced development.” Under the Iskandar masterplan

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prepared by IRDA, the southeastern side of the state had become the
focus, while the southwestern edge was being ignored. 117 Yusof added
that “We have a sultan who is very visionary...he is the one who urged
investors to come in, to convince investors—which is Country Garden – to
come to invest in this area.”
Country Garden’s regional president for Malaysia, Kayson Yuen,
stated that the company studied the project for more than a year before
they decided to invest. 118 If true, this would suggest that the Sultan first
reached out to them some time in 2012, before Country Garden had even
announced its first Malaysian project in nearby Danga Bay. Michael
Grove—a partner at the planning firm Sasaki, which is providing master-
planning assistance for Country Garden—suggested that Danga Bay was
merely “a way to get a footprint early on…build relationships and test the
market.” He suggested that it was “a case study,” implying that Country
Garden had much grander ambitions from the outset. 119
Dr. Serina Rahman suggests that Forest City is part of a larger
political power play by the Sultan. Since the project lies entirely within the
concession boundary for the Port of Tanjung Pelepas (PTP), it seriously
compromises the port’s ability to pursue its current expansion plans. PTP
is operated by federal interests, and has enjoyed historically poor relations
with the nearby kampong communities, who are generally staunch
supporters of the Sultan. Seen in this context, Forest City is a means of
asserting Johor state control over a federal outpost. 120 Even if there are
local impacts, the Sultan could then claim, as he has on several
occasions, that the project is expressly for the state, while the port
represents outside interests. Maimunah Jaffar, the head of planning and
compliance at IRDA, further notes that “anything with no previous legal
ownership arrangement belongs to our king and to the sovereignty of
Johor. That is why reclamation can be the easiest way to bring in
economic growth, because land belongs to the state and most importantly,
it belongs to the Sultan.” 121
Jaffar’s conflation of the state and Sultan speaks to the latter’s
influence, but does not acknowledge the complex web of authorities with
control over the site of Forest City. CGPV reportedly paid a land premium
of RM 225 million to the Johor state government for titles to the marine
area that would become Forest City. 122 Malaysia’s National Land Code
holds that any individual or organization can apply for “any state land.” If
the application is approved, a leasehold title of no more than 99 years is
granted, and a fee, called a “land premium,” is due to the state. The
amount is determined by state assessors based on “market value…which
takes into consideration the land use applied for,” 123 yet comparable cases
suggest that the assessments are drastic underestimations. For its Danga
Bay project, Country Garden spent RM 900 million for a mere 22.26
hectares from Iskandar Waterfront Holdings, 124 a private company headed
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by property magnate Lim Kang Hoo. By contrast, the Sultan reported that
116 hectares of prime land in Tanjung Puteri was valued by the state at
RM 100 million. He reportedly “paid double,” but proceeded to enter into
the deal with Guangzhou R&F that would net him RM 4.5 billion. 125 While
both Tanjung Puteri and Forest City required extensive land reclamation—
which would suppress the value of the title—such dramatic price
differentials suggest that state assessments bear no resemblance to true
market value.
As he had done with Guangzhou R&F, the Sultan entered into a
joint venture with Country Garden Holdings Ltd. to carry out the Forest
City project. The new corporate entity, Country Garden Pacificview Sdn.
Bhd (CGPV) was a 66 percent-34 percent split between Country Garden
Holdings Ltd., the majority shareholder, and Esplanade Danga 88 Sdn.
Bhd., representing the Sultan’s interest. 126 For months, however, the
media reported that Forest City was a joint venture of Country Garden and
Kumpulan Prasarana Rakyat Johor (KPRJ), Johor’s public investment
arm. This concealed—or at least downplayed—the Sultan’s involvement,
giving the impression it was a partnership in the public interest. But
according to corporate filings, KPRJ owned only 20 percent of Esplanade
Danga 88—and potentially less, when the type of shares it was issued
was taken into consideration. The remainder was controlled either directly
by the Sultan or by Daing A. Malek, a member of the royal court of
advisors and the Sultan’s close associate. 127
Speaking well after reclamation began, CGPV executive director
Othman Yusof implied that the Sultan was somehow magnanimous in
voluntarily giving some shares to KPRJ, since “he could have just done it
by himself with Country Garden.” Later asked if it was misleading to
represent KPRJ as the primary local partner, Othman Yusof simply noted
that “representatives of KPRJ also sit on the board of CGPV to oversee
the operations of the company.” 128 The more complete corporate
breakdown only emerged publically in mid-July 2014, as a result of
investigative reporting by independent news outlet Malaysiakini, for which
it won an award. 129
It remains unclear how the Sultan managed to acquire such a large
stake in the project at an early stage. As with Guangzhou R&F, the Sultan
appears to have been given the stake in exchange for facilitating Country
Garden’s venture in Johor. According to Serina Rahman, a resident near
Forest City, “the family of the sultan always gets a stake in these types of
projects.” Furthermore, Rahman adds, “the Sultan is quiet about his stake;
often the race aspect comes out when people are angry it is a Chinese
project, but the role of the Sultan is often ignored.” 130 While clearly
contrived for personal gain, Forest City demonstrates the Sultan’s
adeptness in managing his public image. Early reports of the project
suggested it would house a stadium for the wildly popular Johor football
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team. 131 CGPV is a top sponsor and its logo is displayed prominently on
the team’s jerseys. Rahman concludes that the Sultan is adept at “bread
and circuses,” and ultimately believes that he can act with impunity, since
Johor is effectively “his people and his country.” 132
When Forest City had subsequently stalled to complete its
environment impact assessment, the Sultan lashed out the federal
government for its perceived meddling. Speaking at the opening of a
session of the Johor state assembly, he underscored the importance of
environmental issues, but proceeded to condemn “irresponsible
quarters” 133 who use the EIA as a weapon to stop development. The
Johor ruler suggested that states, and not the federal government, should
have final jurisdiction over environmental matters, and that “a state
environmental body should be set up.” More broadly, the Sultan criticized
external influence in Johor affairs, arguing “Johor is for the people of Johor
and only the people know the conditions and needs of the state, so why
are there outsiders who are trying to interfere.” 134 In another speech, the
Sultan openly criticized the actions of the federal DOE, saying “such
action obstructs the state’s development and causes investors to run
elsewhere.” 135
The Johor Sultan’s interest in land reclamation projects extended
well beyond Forest City. He was also behind the 1,410 hectare Benalec
Holdings Oil Terminal, a project not far from Forest City, to build an
industrial oil and gas hub. The Sultan’s son, Johor crown Prince Ismail
Idris, and his associate Diang A. Malek were named directors of the
project. 136 Furthermore, the Johor Sultan has extensive interests in the
business of sand extraction through the firm Mados Sdn Bhd. It holds
concessions to harvest sand from Raimuna Shoal, off the east coast of
Johor, incidentally where sand for Forest City is being sourced. The
company had earlier come under scrutiny for operating without an EIA in
spite of federal requirements, and preventing fishermen from entering the
concession area. A lawsuit by fishermen proved unsuccessful, but drew
sympathy from Johor politicians, who described their plight as “having
sand thrown in their rice bowl.” 137 The Sultan appears to be involved at
every stage of the value chain.

Lack of engagement and conflict with local

stakeholders
As monumental endeavors backed by powerful interests, urban
megaprojects have been found to undermine processes of public
participation and democratic engagement. Given their status as
“exceptional,” 138 they are not subject to the same standards of public
accountability applied to general urban development. It is clear that Forest
City was conceived of and enabled by the Sultan and an ambitious
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Chinese developer in absence of public review, or even public comment.

The communities closest to the project learned of its existence only when
ships began dumping sand into the Straits of Johor. Virtually everyone
involved—from local politicians to environmentalists and government
figures in Singapore—was taken by surprise.
Yet CGPV’s lack of public engagement continued well after
reclamation began. A public meeting in September 2014 was the
company’s first major community outreach effort, and only occurred as a
mandatory aspect of the DEIA. When they misrepresented the
community’s support, CGPV bore the brunt of public anger. One Star
editorial proclaimed the project—the largest land reclamation effort ever
undertaken in Malaysia—as “a seemingly classic story of rampant big
business, huge profits and nagging controversy.” 139

Lack of engagement
According to teacher and local Kampong Pok resident Baktiar
Jaffar, Forest City was an “instant noodle project”—it appeared out of
nowhere. 140 Though the later EIA claims CGPV consulted locals, he was
not aware of anyone who knew anything about the project at the time
reclamation began. Fishermen similarly claimed that no one in their
villages had been consulted or even notified before barges arrived and
began dumping sand in the Straits. 141 Abu Talib bin Khamis, who lives in
Kampong Pendas nearest Forest City, noted that company
representatives later talked to village heads, but that only came weeks
later. 142 In any case, the village heads neglected to pass on any
information. 143
Opposition politicians, particularly those representing the districts
near the project, were among the first to realize that something dramatic
was stirring in the Strait. Cheo Yee How, DAP Johor State Assemblyman,
recalls that an island suddenly appeared where only water and seagrass
had existed before. 144 He and his colleagues had received no warning or
advanced notice, having instead been tipped off to the reclamation activity
by local fishermen. He and other DAP members—such as Lim Kit Siang
and Boo Cheng Hao—made repeated inquiries of the Johor state
government, but were mostly rebuffed; the government divulged few
details, and simply claimed the project would be beneficial for the state. 145
It was only much later, after Country Garden was forced to complete a
DEIA statement, that they learned details of the project, along with the
general public. The complete lack of consultation was a serious concern
for How and his political colleagues, who couldn’t even find a “signboard
bearing the essential details of the project erected anywhere within the
construction site.” 146 There was a complete lack of public information or
consultation, he claimed.

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Some 9,400 people were estimated to live in the project’s study

area, defined as a 5-kilometer buffer from the perimeter of the Forest City
islands. Most resided in small Malay villages, or Kampongs, which
traditionally consist of large families. More than 60 percent of the
population had resided in the area for 30 years or more. A sizeable
fraction of residents, numbering about 250, were fishermen. The DEIA
consultants estimated that there were 1,880 households in the area, and
devised a 10 percent random sample of household heads, totaling 180
individuals. Their survey found mixed perceptions of the project, with
fewer than 30 percent agreeing it would bring employment opportunities to
their household, but over 80 percent believing it would raise their standard
of living. Virtually all respondents agreed that Forest City would shrink the
fishing ground, and well over half, including almost three-quarters of
fishermen, felt the existing population would be marginalized. Troublingly,
only around 40 percent of the sample interviewed actively knew about the
project, raising concerns that interviewers could easily bias results.
Although the DEIA reports that roughly two-thirds of the respondents
agreed the project was acceptable, the actual survey questions are not
provided. Furthermore, fewer than 10 percent of fishermen agreed. 147
Having been the subject of media scrutiny all summer, Country
Garden faced its first serious public meeting with residents on September
21, 2014, in Kampong Pok. The hearing—a requirement for the DEIA—
went off uneventfully until CGPV began discussing a survey they had
purportedly conducted in the community, which reported that 70 percent of
those interviewed believed the project would be a net positive. Cikgu
Hanifi, a man in the audience, immediately disputed the survey results,
saying that no one in the village had heard about it. While CGPV claims
they took a 10 percent sample of household heads in areas near the
project, many did not believe the levels of support. Indeed, Bakhtiar Jaffar,
who has lived in the community for decades, could not find a single person
who had been interviewed. He reportedly heard that “two of the families
they interviewed were Indonesian.” 148 Local residents claimed it would
lead to the loss of their livelihoods, and accused the developer of
“bulldozing the project through the area without their knowledge.” 149 The
dramatic upwelling of anger and pointed questions took the developer by
surprise.
The media response broadly condemned Country Garden for
appearing out of touch and belligerently forcing its vision on residents.
Reporter Roy K. Nandi argued the project was delayed and complicated
because the authorities did not engage properly with stakeholders.
Despite KPRJ’s (the Johor State investment arm) stake in the project,
“there was no attempt at strategic communication with the stakeholders”
by any of the relevant Johor authorities. At the disastrous meeting in
Kampong Pok, a KPRJ officer had “chided the villagers for being anti-
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development.” The villagers’ willingness to voice their convictions and

speak back to the authorities was rare, and even more remarkable from a
group of traditionally staunch government supporters. Roy saw merit in the
project, but felt it had so far been a public relations disaster: “You cannot
simply move in and expect the people to buy in.” 150

Major stakeholders
In addition to local residents, CGPV also failed to initially engage
with prominent local stakeholders, such as rival property developers and
the Port of Tanjung Pelepas (PTP). Much of what is known about their
subsequent interactions is a result of focus group discussions that were
required as part of the DEIA. Two developers in particular—Sunway
Iskandar Sdn Bhd, and UEM Sunrise Berhad,—distinguished themselves
with dozens of often pointed questions that got to the heart of CGPV’s lack
of communication. Sunway Iskandar, developer of a project in Nusajaya
nearest Forest City, complained that the massive release of units
projected as part of Forest City was not envisioned in various “control
plans,” and therefore would adversely impact the “take-up rate” on their
own development. What had been planned as a 10-year project might now
require 20 years. 151 They asked, with obvious skepticism, if CGPV was
planning to compensate Sunway’s investors, whose investment
expectations now would have to be dramatically reevaluated. UEM
Sunrise echoed this concern, warning of an “unplanned supply of
properties…leading to a collapse in the property market in Johor.” CGPV
claimed in response that Forest City was an “international project” that
would pull from a wide pool of buyers. They suggested other developers
already enjoyed a “first-mover advantage,” and that Forest City would be
prepared for competition. 152
Similarly, PTP argued that Forest City violated the boundaries of its
existing concession and severely disrupted its long-term expansion plans.
PTP would have to forego two additional dock facilities to the east of its
current facility, which it claimed were necessary to accommodate
projected future demand. PTP emphasized its legal right under current
master plans to pursue its expansion objectives, and expressed concern
that it would eventually become uncompetitive with rival ports such as
Singapore if Forest City were allowed to proceed. 153
CGPV responded by underscoring that the project had obtained
legal land titles, and had been formally approved by the state government.
Accordingly, they had “valid and legal mandatory from the authority for this
development.” CGPV made small concessions in resolving a small conflict
involving overlapping land titles and providing some buffer between Forest
City and PTP, but otherwise did not acknowledge PTP’s plans or existing

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rights. CGPV nonetheless expressed hope that the project could

“synergize” to promote regional development. 154

CGPV response
Responding to accusations that they had not engaged with
residents near Forest City, CGPV claimed that several private
consultations had been conducted, and that the public dialogue in
Kampong Pok served as an adequate engagement. Moving forward,
Country Garden committed to fund CSR programs that would vaguely
ensure local communities “benefit from and are able to participate in the
project.” 155 While tacitly acknowledging that the fishermen would lose their
livelihood, CGPV claimed that opportunities afforded by the project could
generate more income for the fishermen than they were making at
present.
CGPV explained its perceived lack of consultation with area
fishermen by pointing to specific “private engagements” through PNKJS
(the Johor fishermen’s association) and “representatives from adjacent
villages.” Without acknowledging any past shortcomings, they emphasized
engagements being conducted as part of the DEIA study, which required
public dialogues. Country Garden also pointed to specific focus group
discussions, all of which were held as requirements of the DEIA. Finally,
they cited a survey conducted among villagers for the DEIA, including
questions on the villagers’ perceptions of the project and whether they
thought the project would provide more advantages than
disadvantages. 156
The glaring shortcoming common to all of CGPV’s statements,
however, is that every single public consultation and engagement they
were citing had occurred long after reclamation had begun. This
comprised even “private consultations,” none of which preceded the start
of the project. 157 Moreover, much of CGPV’s public engagement occurred
because it was mandated under the terms of the DEIA; it is unclear if it
would have happened at all had it not been required. In virtually every
case, rules governing environmental impact assessments stipulate that all
data and social research be gathered well before the development
commences. 158 Given that the project was already underway, it is difficult
to rigorously gauge public opinion on the project; many may have
expressed support knowing its continuation was inevitable. The
widespread lack of information also raises questions about whether
residents were adequately informed about the project to render legitimate
judgments.

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Managing Risk
The literature on megaprojects also points to another central
theme: risk management. The scale of a project heightens the
consequences of both success and failure. Minimizing and managing
uncertainties is at the heart of urban megaproject development. In order to
win approval and maintain a favorable public image, project proponents
often overstate the benefits of their investment and downplay the costs.
For local communities, the burden of a project failure can be
insurmountable. A central component of megaproject risk is damage to the
environment, for which remediation can be immensely expensive and
highly involved.

Benefits and Risks

Again, the history of megaprojects chronicles a tradition of
exaggerating benefits while understating costs. Flyvbjerg found in
particular that urban megaprojects “overvalued local development effects,
and underestimated environmental impacts.” 159 While the Forest City
project is in its early stages, there are nonetheless a variety of reasons to
believe that it too will fit this pattern. Justifications given for the project
hinge on attracting development providing numerous job opportunities, but
the details are either unclear or highly optimistic. Estimates and
projections—even those provided by Forest City proponents—have varied
widely. Many do not hold up under scrutiny. There is also systemic risk
that a failure in Forest City could sour investor sentiment, and jeopardize
development across the Iskandar Malaysia region.
At the same time, governments have shifted away from launching
megaprojects themselves, instead courting private sector involvement
through inducements and development incentives. 160 Often, a private
developer will partner with the government or public entity. With private, or
at least semi-private interests leading development, there are concerns
about the “privatization of planning” 161 and a lack of public accountability.
As a private development, located in Johor at least in part due to the
incentives and favorable investment climate of Iskandar Malaysia, Forest
City aligns closely with this model.

Forest City’s statement of need

The Forest City DEIA sets out a sweeping and multifaceted
justification for the project. Forest City is portrayed as key to “the potential
of opening international investment opportunities which would then propel
Johor’s economy as the main gateway in the South of the country.” The
project will offer job opportunities for the surrounding communities,
creating a “better and more secure life for all through income generation
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and high-quality facilities and infrastructure.” Furthermore, “it would likely

provide a new dimension towards the creation of modern business and will
be an example and benchmark in the development of similar townships
and centers in the future” 162
The problem with such statements is that they are inherently
speculative in nature, and lack specificity or objective criteria for
evaluation. The Forest City DEIA made no effort to quantify the amount of
foreign investment the project would generate or detail its broader
economic impact. Statements by CGPV representatives have remained
similarly vague, stressing how Forest City will “diversify incomes” and
“improve the quality of life.”163
Ironically, the DEIA also argued that the project would strengthen
Malaysia-Singapore bilateral relations. Forest City had the potential to
“attract investors from land-starved Singapore to commit international
investments as a way to benefit from the planned facilities and thereby
result in gains for both countries.” In fact, as it turned out, the project
“ruffled Singapore-Malaysia ties.” 164 It raised concerns in the Singapore
government over transboundary impacts, which were serious enough that
Singapore immediately demanded more information, including an EIA
report, and sent at least two high-level diplomatic notes. Singapore argued
that “Malaysia should not permit reclamation activities of this scale…so
close to Singapore without first conducting an environmental impact
assessment.” 165 The issue was considered sufficiently weighty to reach
the highest levels of government. Singapore’s Prime Minister Lee Hsing
Loon reportedly wrote to his Malaysian counterpart, Najib Razak, who
faced a “serious dilemma” on how to address Singapore’s concerns. 166
To many observers, Forest City threatened a recapitulation of a
previous dispute over land reclamation in 2003 that reached the
International Tribunal for the Law of the Sea. In that case the roles were
reversed, as Malaysia protested Singapore’s reclamation efforts at Tuas.
Although that case was settled amicably, some Johor lawmakers feared
“retribution” and worried that the two nations could become embroiled in a
“diplomatic row.” 167
In its statement of need, CGPV emphasized that the Forest City
project would involve RM 700 million in “infrastructure upgrading works” in
the areas surrounding the proposed project. The road and public
transportation systems in the communities of Gelang Patah, Tanjung
Pelepas and Nusajaya would be the primary beneficiaries. Yet this amount
is a negligible fraction of the RM 450 billion gross development value, and
consists primarily of upgrading roads to serve the development. Hana
Badriah, a planning officer at IRDA, noted that road construction “will
accompany greater amounts of traffic, so I’m not sure it is a very strong
rationale.” The DEIA suggests that a six-lane access road will be required
to link Forest City with the region’s existing highway network, while other
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local roads will need to be widened to four-lane dual carriageways. These

upgrades, even if financed by CGPV, will have myriad impacts of their
own and dramatically alter the character of the Tanjung Kupang, the Johor
district closest to Forest City. Since expressway construction is a
“prescribed activity” according to Malaysian environmental law, it is
possible that Forest City’s access roads would themselves demand an
environmental impact assessment. There is no indication of the costs of
these road projects or how the proposed RM 700 million in upgrades
would be budgeted.
Forest City has a projected population in the hundreds of
thousands, 168 yet CGPV has given few indications of the immense
supporting infrastructure required and how it would be financed. In its
focus group discussion with Johor stakeholders, CGPV declined to
address whether Forest City would result in “constraints” or “bottlenecks”
in utility supply for other developers. It claimed that as a “30 year project,”
it would “work with the relevant authorities to incorporate the entire
development to ensure sufficient capacity.” CGPV ultimately placed
responsibility with the local authority, which would be required to “ensure
smooth construction and supply to the project along the pipeline.”
According to Hana Badriah, in meetings with IRDA, CGPV responded “to
every question about how they would provide power, water and other
things [by saying] that they would tap into the current system.”
While existing infrastructure may have been sufficient for smaller
projects, the scale of Forest City suggested they “need to do something
more.”169 As a case in point, Forest City’s projected water consumption is
around 40 mgd (million gallons a day), more than a fifth of all the domestic
water consumption in Singapore. 170 Yet as of summer 2015, Johor has
faced water shortages and record low reservoir levels that have prompted
rationing programs. 171 For a project of its size, Forest City has not
adequately addressed how its infrastructure requirements integrate with
those of Johor.
Comments from Jeffrey Yee, an executive at rival Chinese
developer Guangzhou R&F, reveal that the very different development
environment in China may account for CGPV’s casual approach to
meeting infrastructure needs. In China, according to Yee, townships are
planned ahead by the government, and a non-negotiable contribution fee
covers all infrastructure connections. The developer only needs to interact
with local representatives of the state. In Malaysia, the situation is very
different. Yee reports that Chinese executives at his firm ask “why do we
have to deal with so many agencies?” They are required to interact with
the state, local authority and the federal government—a very different
state of affairs than what they are accustomed to in China. 172

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Economic case
The economic case for Forest City hinges on creating job
opportunities for surrounding communities and more broadly in Johor. Yet
predictions of the number of jobs generated span a wide range. The DEIA
gives a figure of 62,200, which aligns with statements from CGPV
executive director Othman Yusof in September 2014. By March 2015,
however, Yusof estimated 200,000 to 250,000, even as the project’s gross
development value was revised downward by 30 percent. 173 Subsequent
reports have also used this range, adding that Forest City would also
provide free education to locals in vocational and technical schools. 174
This more recent estimate is comparable to estimates of Forest City’s
projected population of 300,000.
Since nearly half the project is devoted to residential use, while only
a quarter is commercial, there is reason to conclude that such jobs figures
are unrealistically high. 175 Furthermore, Hana Badriah at IRDA questioned
whether the types of jobs available would be suitable for local residents:
“the jobs that I think they will create really don’t appeal to Malaysians
anyway.” 176 Construction and basic service jobs are relatively low paying,
and are mostly filled by migrant laborers.
After action from the state government, CGPV agreed to contribute
to a fund that would support fishermen affected by reclamation works. Yet
they were ultimately unsympathetic to their cause, implying that the
fishermen and villagers were backward people who needed to
“modernize.” While they would provide some compensation in the near
term, they argued that in the future fishermen would need to “change to an
alternative venture of becoming modern fishermen.” They actively
suggested that young generations should be “steered away from
becoming fishermen and engage in modern sectors and industries.”177
Naturally, they considered opportunities in the Forest City project
implementation a “viable option.”
Yet for people who have maintained a way of life for generations, it
is no small order to retrain and integrate into the larger capitalist economy
as service workers. Furthermore, because of internal politics and the
particular hierarchy of the Fishermen’s association, which would collect
the funds from the state government, the benefits would be distributed
unevenly. 178 Those who were career fishermen but lacked a particular
license would receive nothing, while others would receive a one-time
payment.
Estimates of the project’s population have a similarly high degree of
variability. Sources report the Forest City population ranging from 300,000
to 700,000. 179 Even at the low end of this range, given that roughly half of
built space will be residential, the population density would be comparable
to some of the most crowded urban areas in the world—central Manila

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and Hong Kong. 180 While the width of the range is troubling, the implied
density would effectively undermine the salubrious, open vision presented
in Forest City’s promotional materials. Green space is only to occupy 12
percent of the project, despite images of endless greenery and spacious
common areas. 181
Financing a project the scale of Forest City also raises legitimate
questions. As of September 2014, CGPV’s “current authorized paid-up
capital” was only RM400,000 and was presumably operating with just
enough funds to cover the costs of reclamation. CGPV executive director
Othman Yusof claimed “we will initiate discussion with potential financiers
as soon as we have obtained our DEIA and planning approval. Potential
financiers will be both local and international. For the time being, all funds
are [being] generated by internal financing.” Later, in fall 2015, reports
emerged that CGPV was issuing a “sukuk” or Islamic bonds of at least RM
1 billion, potentially in an effort to reduce foreign exchange risks. Reports
indicated that it was a “tough sell,” given perceived oversupply in the
market, and that the company would have difficulty “convince[ing]
investors to take a credit risk.” 182
Past urban megaprojects have a mixed record, with many high-
profile failures. Changing economic circumstances can spell the end for
even the most promising projects. In the wake of grand ambitions are left
“ghost cities,” such as Muang Thong Thani outside Bangkok. Yet in its
DEIA and throughout its public comments, CGPV has reliably neglected to
mention the risk its failure could pose to the many other projects in the
region and possibly even the Iskandar Malaysia enterprise as a whole. In
this vein, an executive at rival Chinese developer Guangzhou R&F, Dr.
Jeffrey Yee, said that he earnestly hoped Forest City would succeed: “As
a competitor, I wish that all the developers will be successful. If I see one
of these fail it will impact adjacent development—investors will be thinking
about related cases and examples. One failure could undermine the whole
premise of development here.” 183
Since Forest City entered the scene unannounced and external to
any comprehensive plans, it is highly disruptive to nearby developers,
such as UEM Sunrise and Medini Iskandar, which worried that Forest City
will cause an oversupply in the property market. 184 Despite CGPV’s
assertions that Forest City is an “international project,” and hence will
draw from a different pool of buyers, the promotional materials of these
other projects suggest that they are targeting a similarly affluent, worldly,
and “international” clientele. 185 Moreover, the scale of reclamation
involved in Forest City prompted worries at UEM Sunrise that it would
disrupt views, restrict access for boats anchoring in Medini Harbor, and
otherwise undermine its development. 186 CGPV’s claims to benefit the
region must be viewed skeptically if those benefits simply come at the
expense of existing projects that are integrated in a comprehensive plan.
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“Do no harm”
Forest City reflects many of the trends affecting megaprojects that
have come to characterize the modern era of large-scale urban
developments. Following a disastrous record of large-scale urban
development interventions—through programs such as urban renewal—
megaprojects have sought to mitigate impacts as much as possible, or at
least give the appearance of doing so. Whereas in the past projects would
be approved if overall benefits outweighed costs, including displacement
and environmental damage, now they are given more scrutiny. Ironically,
while Forest City may have tremendous impacts on the natural and social
environment of its surroundings, aspects of the project also align with this
modern “do no harm” 187 paradigm.
Forest City’s reliance on exclusively reclaimed land makes a strong
case for a development strategy that strives to minimize displacement and
impacts on existing land. As an “international project,” Forest City
demanded a high-value coastal site, but even this did not necessitate such
a large degree of reclamation. Dr. Jeffrey Yee at rival firm Guangzhou
R&F was baffled as to why Forest City was being reclaimed as an island:
“You could always extend the shoreline at much lower cost.” While other
projects in Johor involved land reclamation, including Country Garden’s
previous Danga Bay venture, none planned to build exclusively on new
land. CGPV’s published answers to public questions are therefore telling:
“To make sure the project creates economic benefits and is viable, the
project proponent needs a sizeable land bank. Reclamation is the best
alternative when all aspects are considered, including to minimize the
social impact due to land acquisition.” 188
While land reclamation would ironically become associated with
social impacts on fishermen, it seems the decision was made to minimize
public friction and opportunities for opposition. Even considering the
immense cost of reclamation, it must have been seen as preferable to
skirmishes with villagers over their land. In a public statement, Othman
Yusof echoed this sentiment when claimed that acquiring existing land
would create a list of social grievances through displacement. 189 A
separate CGPV FAQ notes that the scale of the project necessitated a
large land bank, which could be assembled most easily through
reclamation. They argued that this would minimize overall social
impacts. 190

Environmental damage and threats to sustainability

Several authors have characterized urban megaprojects as serious
concerns for urban sustainability, whether in the form of sprawl or threats

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to the natural environment. 191 As tremendously scaled projects, their

impacts can be correspondingly immense.
Forest City, while still in its early stages, has already exacted a
substantial toll on the natural environment. For the first several months,
reclamation proceeded without any form of ecological mitigation, which
caused lasting harm to the seagrass bed. While Forest City terms itself an
“ecological” development, the project is not sustainable in any
comprehensive sense. As Gardner argues, true sustainability must
encompass the entire urban realm and not selective portions. Even if the
project provides internal public transit, for example, it is still dependent on
the automobile to connect anywhere outside the development. The
project’s arrival outside comprehensive regional development plans
exacerbates this disconnect. Finally, Forest City’s reactive planning—
adjusting its project quickly to suit the market—raises questions of how
CGPV can accommodate sustainability objectives while simultaneously
adjusting to the market.

Environmental threats posed by Forest City

The Forest City DEIA acknowledges the environmental and
ecological significance of the Forest City site, drawing particular attention
to the seagrass beds. Ironically, then, the report admits that the first phase
of the project was “conducted without considering inputs from hydraulic
and environmental assessments.” CGPV made use of almost no
“mitigation measures” during this phase, with the result that “significant
environmental impacts” occurred on the site. The most egregious case
involved an access causeway built by dumping sand directly on the
seagrass that “completely destroyed” 3.96 hectares of the bed, splitting
the valuable ecosystem in two. 192 Local observers and environmental
advocates suggest that the impact on the eastern portion of the seagrass
was in fact much greater than even the DEIA admits. The causeway
blocked currents that flush sediment through the region, which had by
August 2015 already decreased both the diversity and concentration of
seagrasses in the area. 193 Although CGPV committed to “undertake
necessary rectification works,” 194 including the complete removal of the
causeway, as of August 2015 it was still in place. 195

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Figure 6. Merambong Shoal seagrass bed and the initial Forest City reclamation.
Source: Forest City DEIA Vol. 3

Marine researcher Dr. Daniel Freiss of NUS (the National University

of Singapore) explained that since sand “tends not to float very far” the
primary worry associated with Forest City involves large-scale changes in
hydrology. 196 The long time frame of the development—estimated at 30
years—poses the greatest long-term risks. Intuitively, marine ecosystems
can sustain stresses for limited periods of time and recover, but nowhere
near the time needed to construct new islands housing several hundred
thousand people. Even when completed, it was unclear how pollution and
the release of sewage would impact the environment. Fundamentally, it is
impossible to accommodate half a million people (or more) in the space of
a few square kilometers without significant impacts of some kind. 197
If and when the full plan for Forest City is realized, the seagrass
bed will be completely encircled by islands, isolating it from the coastal
mangroves. There are mutual connections between the mangrove and
seagrass communities, so there will likely be severe negative impacts on
the seagrass bed. 198 The Forest City DEIA itself admits that “in order to
protect the seagrass beds, the mitigation measures proposed must be
properly planned, flawlessly implemented, and reliably maintained.” 199
Previous efforts to replant seagrass have not borne much fruit. As Dr.
Freiss notes, “if there was a suitable relocation site, it would already have
seagrass on it.” 200

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Forest City DEIA and environmental monitoring

The Forest City DEIA came under heavy criticism from a range of
researchers and environmental advocates. Ironically, the same company
that Country Garden retained to complete its DEIA—Dr. Nik and
Associates—contributed to the Iskandar Malaysia Shoreline Management
Plan, which established that no further development would happen on the
site. The firm was presumably put in the unenviable position of having to
justify a project that ran entirely counter to an environmental plan it
previously had helped shape. 201 Vincent Chow, adviser to the Malaysian
Nature Society, criticized the Forest City DEIA on the grounds that it
lacked scientific data and did not adequately address the impact of large-
scale reclamation on the Straits of Johor. Most data were from secondary
sources and not collected specifically for the study, he noted. The report
mentions serious sediment impacts on the Johor Straits, but did not
indicate which seagrass species would be affected, or how long they could
survive the sediment-related stress. 202 Additionally, Chow insisted that the
proposed mitigation measures were not sufficiently detailed, a perspective
shared by environmental researcher Lena Wong of UPM (Universiti Putra
Malaysia). 203
Save our Seahorses, an environmental NGO based in Johor, felt
the DEIA was “inadequate,” and did not fully address their concerns for
the seagrass bed. They were heartened that the new landform of the
project no longer covered the seagrass, but felt much more monitoring
and mitigation was warranted. 204 A UPM researcher who was later
employed in monitoring work by Country Garden, Lena Wong, questioned
how a DEIA report could be completed over the span of just a few months.
A year or more is necessary to capture the full extent of seasonal
variation, she argued. She, like Vincent Chow, noted that most of the data
was qualitative, and so was useless as a basis for environmental
monitoring. Lists of species were provided, but there was no data
concerning distribution or relative frequency. She suspected that “it is
mostly old data” the consultants “threw together.” 205 Bakhtiar Jaffar also
questioned the legitimacy of data collection based on his conversations
with fishermen who ferried the consultants out in their boats. They
reportedly recorded GPS points for the project in a haphazard fashion and
just had the fishermen take them “wherever.”
Lena Wong, who is working as part of a team to conduct
environmental monitoring at the Forest City reclamation site, went on to
question the authorities at the federal DOE, suggesting that “we can write
anything we want in these reports since no one there seems to care.” 206
She and Bakhtiar suggested that ministers at top levels may not have any
real competence in their supposed department, since they are frequently
shuffled around. She questioned whether anyone on the panel reviewing

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the Forest City DEIA was knowledgeable enough to interpret and revise
the document. They had apparently provided a number of monitoring
recommendations that “just don’t make sense.” 207
Meanwhile, local politics has compromised the DOE at the state
level. Bakhtiar alleged that the former state executive for the environment
had been “hiding” after blocking too many high-profile projects. New
projects are now not subject to significant review, he claimed. Monitoring
for the project also came under question. Some of Country Garden’s
remote monitoring stations were set a great distance from the reclamation
site, presumably so they would remain in clear water and fail to register
any disturbances. 208

Forest City in the context of sustainability in Iskandar

Malaysia
A Forest City promotional brochure suggests that the development
is “surrounded by more than 10 km of coastline encircling a 130-acre
seagrass reserve with fresh air and pristine waters.” 209 In fact, if
surrounding developments proceed as projected, the project will be
surrounded by a bevy of heavy industrial uses. The expanding container
port of Tanjung Pelepas lies to its immediate east, with strong projected
growth as it vies with Singapore for a greater share of marine traffic.
Farther east, reclamation is underway for an oil and gas terminal by
developer Benelec Holdings. Across the Straits of Johor sits Tuas in
Singapore, an industrial and warehouse district. Around 5km from the
easternmost of the Forest City islands is a live fire facility in Singapore. A
visit to the mainland near the Forest City site suggests that the sounds
from munitions testing are quite audible. 210
Forest City promotional materials suggest that it will be an “island
oasis that grows organically” and “technologically advanced with low
carbon emissions.” It will include “sustainable and renewable energy
infrastructures” that foster “sustainable green urbanism,” all contained in a
“three-dimensional urban forest.”211 Yet experts with knowledge of CGPV
suggest that such promotional copy is not rooted in reality. To Lena Wong
and Bakhtiar Jaffar, CGPV seemed to have very little knowledge of
environmental issues. 212 Indeed, the initial plan for Forest City involved a
monolithic single landmass that would have completely smothered the
seagrass and caused much more dramatic impacts on local hydrology. 213
Michael Grove, the Sasaki principal who worked with CGPV in the master
planning stage, noted that “there was no idea about sustainability, about
ecology, about any kind of environmental factors beyond the very basic
environmental impact assessment process that they had to go through.”
He perceived a disconnect between their understanding of the physical
construction and engineering side of the project—which they know very
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much about—and their understanding the environmental and political

issues that they were facing.” 214
Country Garden’s projects in China include a handful of green
elements, but these hint at a superficial understanding of “sustainability.”
Sasaki’s Michael Grove pointed to the Country Garden headquarters in
Foshan, where the notion of green building involves “slapping some
vertical green walls and hanging planters on the side of a very traditionally
constructed building without all of the advanced technologies that we
would think of as a Living Building, which is how they like to frame it, but
it’s really not.” Moreover, Country Garden’s previous Johor project, in
Danga Bay, does not suggest a particularly “ecological” approach to
landscape. Summarizing the approach, Michael Grove suggested “it
leaves a lot to be desired.” It includes a generally eclectic range of
vegetation, much of it non-native, and clearly requiring intensive fertilizer
and maintenance by grounds staff. Even so, Grove articulated an
optimistic vision for Forest City:

I’m hoping that’s going to be different at Forest City because

it is this huge coastline with a lot of opportunity for a public
realm and an edge condition that would not only support the
community but increase the value of the real estate within
the island but also increase the potential for habitat value in
the surrounding area as well. 215

While there are many inconsistencies, CGPV appears to be taking

some aspects of its sustainability rhetoric seriously. In December 2015, for
example, the company engaged G-Energy, a Singapore-based
environmental consultant with a specialty in green building and rating
certifications. The firm, while unaccustomed to working at quite the scale
of Forest City, aims to achieve Greenmark certification for the entire
Forest City plan. Greenmark is similar to the better known LEED
standards, but is reportedly better adapted to tropical climates like those of
Singapore and Malaysia. 216 While individually green buildings are
encouraged, G-Energy’s certification effort centers on plan-level priorities,
like the reach and accessibility of the public transit network and the siting
of various districts within the project. 217
G-energy is working with both passive and active design strategies
to minimize energy use and resource requirements. Leo Cher, an
employee at G-energy, felt that CGPV is earnestly pursuing environmental
credentials: “this is a daring move for them, since no other developers are
going after green certification for a project like this…it has a lot of risks,
especially since they are not familiar with the requirements and it is not a
common thing for them in China.” 218 Moving forward, Cher felt that green
credentials were more of an effort to attract Singapore buyers than
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mainland Chinese. It appears to be more than pure promotion; Greenmark

standards are reportedly quite strict and involve field verification of
performance claims. 219
Some of the challenges to sustainability that the company faces are
largely outside its control. The development sits in Iskandar Malaysia,
which promotes “sustainable development” and “conservation of the
environment.” 220 Yet in practice, the region’s patterns of development do
not reflect these aims. Johor Bahru is largely automobile-dependent, with
very limited public transportation. Even a dramatic expansion in public
transit may be of limited effectiveness, since most of the region is low
density and most new development occurs on greenfield sites. 221 The
University Tecknologi Malaysia sprawls over such a large campus that
bicycles and buses are required to travel from dormitories to classes. 222
Well before Forest City, planning decisions have demonstrated a lack of
environmental sensitivity. Around Danga Bay, for example, a six-lane
highway was routed directly through mangrove habitat. 223 Placed in this
context, Forest City can at best become a sustainable enclave, though the
carbon intensity of the luxury lifestyle of its projected buyers suggests that
even this will be difficult to achieve.

Sustainability and reactive planning

A reactive or “dynamic” planning approach is central to Forest
City’s development strategy, but raises doubts about CGPV’s ability to
pursue its sustainability objectives. CGPV aims to continuously adapt its
development to market conditions, building more or less of specific real
estate products based on which are selling most successfully. As land
reclamation and building de novo involves great fixed costs, CGPV is
compelled to adapt quickly in order to maintain an adequate cash flow. 224
While defensible from an economic perspective, the dynamic strategy may
undermine master plan-level considerations with important implications for
the overall sustainability, efficiency and—ultimately—livability of the
project.
Anticipated public transit routes, for example, may be impossible to
co-locate with the greatest concentrations of people if short-term
development necessitates more low-rise villas. Too little land may be
available for commercial space if residential apartments prove to be
extremely popular. Countless other such scenarios could be imagined.
Ultimately, an ad hoc approach is the antithesis of planning.
Country Garden is distinctive as a purely private developer
undertaking such a massively scaled and ambitious project. Other
Chinese developers active in Johor, such as Greenland, are state-run
enterprises. Among urban megaprojects around the world, certainly the
vast majority have been developed by public entities, or through public-

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private partnerships. Both Nakheel, developer of the famous Palms in

Dubai, and UDC—developing the Pearl in Qatar—have heavy state
involvement. 225 Elsewhere in Southeast Asia, Saigon South is also the
product of a public-private partnership. CGPV executive Dr. Runze Yu
explained some of the distinct challenges they faced as a solely private
developer undertaking such a comprehensive project:

You rarely encounter people who have experience on how a

private sector—100 percent pure private sector [firm]—can
do an urban plan for such a massive project. Usually, it’s a
job by the public sector or the government and they already
have something on the ground. So you say that this is the
urban center, this is the old town and we could put a new
town there. This is the industrial there and this is more like
commercial, right? So you already have a plate of things and
you then move things around and see what would be the
development try to look like, what would be the policy. 226

Beyond the issue of expertise and experience, CGPV was

constrained by economics and the reliance on private financing. Dr. Yu
stressed that “we don’t really have tax revenue like the public sector or
can charge people for whatever. The only revenue we have is our
sales.” 227 Reclaiming land has added to the dilemma, by providing a blank
slate for a vast range of development possibilities. In order to “survive,”
the company needed a flexible and responsive strategy. As Yu puts it:

You have to maximize your profit to make yourself

sustain[able]. So that really changed the landscape of the
project a lot. You never know what’s going to happen even
next quarter. How much we want to reclaim, the land use
and so on. Maybe in the current plan it’s CBD but then we
find villas sell good and then we just convert it into a
residential for landed [property]. 228

Drawing comparisons to the planning process in Singapore, where

the master plan is revised every five years, Dr. Yu explained that Forest
City may require revisions “every quarter.” Economics were to be a driving
force, but this also created tensions with other development priorities such
as public facilities. It also prompted worries about the character of the
place they were creating. Dr. Yu admitted that this was a problem with no
easy solution:

Right, so every day we look at the data of the sales and we

are trying to analyze what are the good sales. But we also
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don’t want to make this like a bedroom town. We need to

reserve land for international schools and hospitals. In the
early stages it’s hurting the project because we are taking
lots of low-density land area. It’s opportunity cost; we are not
building those residentials, we are building schools and
hospitals that are also needed. So you see the conflict here?
On the one hand you need to make money and survive, and
on the other you have to balance the entire city
development. That’s the challenge number one is the
dynamic planning. I don’t really have an answer. 229

Consultants working with CGPV recognized this tension between

economics and planning as a significant challenge, and expressed
concerns in particular that it could compromise efforts to make the project
more sustainable. Michael Grove at Sasaki described a “disconnect
between what we want to do as planners concerned about the long-term
sustainability of this place…[and how it] relates to their short-term
construction schedule of just getting something built and open.” Grove
worried that his team’s efforts to consider storm water, “edge conditions”
and new habitats conflicted with the exigencies of CGPV’s economics. 230
Similarly, Veron Ng of green consultants G-Energy worried that
“they will have some difficulty being true to the entire concept.” Given their
tremendous ambitions, “we fear they might be tempted to compromise or
forego certain aspects or recommendations if they run out of time or
money.” She noted that Chinese developers are comfortable working at
immense scales, but as a result may ignore their detailed
recommendations. Agreeing with Dr. Yu’s outlook, she suggested that
CGPV was practicing “design on the go,” based on immediate
demands. 231

Marketing of Forest City and the language of

globalization
The creation of Iskandar Malaysia as a special investment zone is
tightly bound up in the larger processes of globalization. As international
capital is perceived to be more mobile, rhetoric has shifted towards urban
competitiveness, stressing the need attract foreign investment so that a
city can edge out its global peers. 232 The associated notion of “global
cities,” given weight by world city rankings, underscores the importance of
becoming a node in the international system of commerce and investment.
Cities and metropolitan regions are expected to be “entrepreneurial” in
their own right if they are to remain relevant in the global hierarchy. As a
consequence, some argue that urban regions are being reconfigured to
meet the needs of affluent outsiders, instead of the needs of their own
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local populations. Urban megaprojects play a leading role in this

process. 233

Language of globalization
Language from agencies and documents throughout Iskandar
Malaysia explicitly engages with these themes. The 2006 guiding master
plan for the South Johor Economic Region, later to become Iskandar
Malaysia, speaks of how the federal government “identified a need for a
focused and developmental approach,” which “had taken into cognizance
the dominant trends of our times including globalization with its increased
competition in the flows of capital, human resources and ideas.” 234 The
plan identifies Johor’s specific advantages, including strategic geography,
low-cost land and labor, and strong connectivity to other regions, but
warns that such factors “unchecked and unmanaged…represent
significant threats to the enduring prosperity” of Johor. 235 Similarly, IRDA’s
mission statement emphasizes the need to transform the region into a
“metropolis of international standing.” IRDA explicitly exists to facilitate
investment by “monitor[ing] the development of economic sectors,”
expediting approvals, and promoting Iskandar Malaysia. 236
Urban megaprojects represent a fundamental component of efforts
to bolster regional competitiveness and attract investment. In both the
structure of the project and the language used to describe it, Forest City
assumes this role for Iskandar Malaysia. CGPV on numerous occasions
has pronounced Forest City an “international project.” 237 One brochure
describes it as a “future city with global vision.” 238 A promotional video
goes further, claiming it will be “a pride and dream paradise for all
mankind.”239 Aligning with the rhetoric of regional promotion, a Forest City
brochure explains the project will enhance “Malaysia’s emerging status in
the world.” 240 Predictably, CGPV also makes a great deal of Forest City’s
economic integration and linkages throughout Southeast Asia and beyond.
One brochure, for instance, emphasizes how the project fits within China’s
larger “one belt one road” initiative, that proposes to link Asian economies
in a modern-day reincarnation of the Silk Road. 241 In the spirit of
international integration, Forest City is projected to “deepen the economic
and trade cooperation between Malaysia and Singapore.”242

Marketing “world class”

According to its advertising, Forest City abounds with the trappings
and conveniences expected to attract worldly and affluent buyers. A duty
free zone on one of the islands is described as an “international shopping
paradise.” 243 It will possess a “world-class” theme park. Financial and
scientific institutions will cater to “intellectually advanced populations.”
Residents can expect medical and health industries that even include
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“Swiss anti-aging” expertise. 244 CGPV highlights a memorandum of

understanding with Shattuck St. Mary’s school, a private US boarding
school near Minneapolis, which is part of creating a “top notch education
city.” 245 It will also reportedly include a “media industry,” “marina port,” and
business and financial districts.” 246 At the same time, the project
emphasizes its exclusivity. It has “closed management” and “smart
security systems,” presumably intended to prevent undesirable people
from entering. 247 Amidst the endless list of amenities, one may well ask
what the project does not provide. CGPV claims it has everything needed
to “promote mutual integration as a symbiosis of capitalism.” 248 That
statement underscores the powerful market forces that appear to shape
virtually every aspect of the project.
Inconspicuous or absent in much of Forest City’s promotional
materials are references to aspects of Malay culture or heritage. Mosques
and prayer halls make scant appearances. Most of the people featured in
its brochures and videos appear to be of Chinese or European origin.
Architecture throughout the project makes no reference to regional
influences, instead relying on greenery-clad, glass skyscrapers and villas
reminiscent of Californian suburbia. 249 While CGPV promotes Forest City’s
“wonderful seaview,” and touts its environmental credentials with
“seagrass, wetlands, and mangrove conservations,” the images
associated with such descriptions appear to be of tropical islands that bear
little resemblance to coastal Johor. 250 Beyond references to Iskandar
Malaysia economic incentives, promotional materials make almost no
reference to communities surrounding the project, or to other urban
centers in Johor Bahru. Iskandar Malaysia is described in terms of recent
projects including Legoland and the Johor Premium Outlets; otherwise,
the marketing imagery is focused on Singapore, with glossy spreads of
Supertrees and the Marina Bay Sands development. 251
Combining its own investment incentives with those of Iskandar
Malaysia, Forest City presents a remarkable suite of economic
inducements. Freehold property in Forest City is advertised as a quarter
the price of Singapore with no inheritance tax. 252 Among many benefits, it
is asserted, investors enjoy “property gain tax exemptions,” “import/sales
tax exemptions,” and reduced tax rates for expatriate workers. Businesses
can hire an “unrestricted” supply of foreign workers, while also enjoying
corporate sales tax exemptions and exemptions from foreign equity
restrictions. 253 Meanwhile, the project is not subject to standard
bumiputera quotas that set aside a portion of developments exclusively for
Malays. 254 It is also considered an “international zone,” where a minimum
purchase price of RM 1 million for foreigners does not apply. Country
Garden’s CEO Mo Bin claimed that the company had “received [a] state
waiver for that requirement.” 255

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Figure 7. Rendered scene from Forest City depicting yachts, sailboats and other
markers of an elite lifestyle 256

Forest City’s marketing targeting international elites, its tax

incentives, and its exemption from requirements intended to support local
residents all point to the “repackaging” 257 of urban space for outsiders.
The price of units in Forest City places them out of reach of all but the
most affluent of Johor residents. Basic studio units sell for RM 500,000,
while the median Malaysian salary is around RM 55,000. 258 A handful of
local residents may be able to secure employment in Forest City, although
the lack of limits on international workers suggests they would face stiff
competition. Many, such as the fishermen, would have to be thoroughly
retrained to suit the available opportunities. 259
If the project’s population predictions are accurate, a large fraction
of Iskandar Malaysia’s residents may one day live in Forest City. Yet, the
development is entirely planned and executed by private interests. Within
legal limits, CGPV enjoys complete freedom to shape the development as
it chooses, without established mechanisms for democratic engagement
present in developments elsewhere in Johor. If, as CGPV claims, Forest
City is to be “a model for future cities of the world,” 260 it leaves open many
questions surrounding urban governance.

Transfer agents and policy mobility

CGPV has partnered with a number of high-profile international
consulting firms to guide its work on Forest City. Sasaki, mentioned
earlier, contributes design and planning expertise; while McKinsey will
conduct market research and Deloitte will consult on “resource
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management and strategic planning.” Meanwhile, CGPV is partnering with

Huawei to craft a “smart city” strategy that encompasses connectivity and
seamless integration of technology. Such firms are sometimes referred to
as “transfer agents,”261 because they facilitate the spread of policy and the
proliferation of norms regarding “global cities.”
This is true for Forest City. Most of the firms working with CGPV
have advised numerous other projects of similar types and scales. As
expert “epistemic communities,” they have an outsize influence on the
standards and signifiers that denote “world class.” 262 Michael Grove at
Sasaki acknowledged having worked on plans for other large
megaprojects, including Thu Theim in Ho Chi Minh City. While not quite at
the scale of Forest City, the project involved “creating a new CBD and all
of the infrastructure.” Previous experience with cities in China had also
“given us insight into what it takes to create a large new city with a mix of
uses and transit.”263 While G-Energy does not enjoy quite the same global
prominence of CGPV’s other international consultants, they also brought
experience from other large-scale projects. For example, G-Energy
assisted with the district-level plan for Sentosa Island in Singapore,
achieving a gold+ rating from Greenmark. 264

Discussion and conclusions

Appropriating blame
While it is clear that Forest City has caused numerous
environmental and social impacts, Chinese developer Country Garden
Holdings Ltd. should not be the sole target of blame. As outsiders, they
relied on local partners and agencies to help them navigate the approvals
process and remain in compliance with the relevant regulations.
The ultimate failures, it seems, occurred at the institutional level in
Johor. The Department of Education (DOE) failed to uphold its own
regulations and permitted the project without review. Local councils
prioritized development over the environment, and likely experienced
political interference from the Sultan or his associates. A legal framework
that includes state ownership of land and a federal DOE with limited
capacity exacerbated the problem by limiting the federal government’s
ability to intervene. In fact, far from being a malicious actor, there are
indications that Country Garden regretted its initial missteps in burying the
seagrass, and attempted to make amends. There are also suggestions
that the Port of Tanjung Pelepas (PTP) was complicit in the project. DEIA
consultants, meanwhile, were under their own distinct pressures.

Regulatory and institutional factors in Johor

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Every development project, especially those at the scale of Forest

City, must pass through a number of agencies and approvals. The Johor
State Department of Environment stood as a gatekeeper with the authority
to demand proper assessment of the project and its impacts well before
the first sand was dumped into the sea. Again, given the Sultan’s personal
interest in the project and his considerable influence in state affairs, it
appears likely that he or proxies interfered in the DOE’s operations. 265
Through cronyism or other means—the mechanism ultimately remains
unclear—the DOE failed in its responsibility to protect the environment. It
neglected to implement its own regulations and protocols. 266 As UPM
marine researcher Lena Wong acknowledges, “The state DOE should
have known, but clearly they didn’t make it known or make [the seagrass]
a serious priority.” She feels that the state should have made
environmental expectations much more clear. 267
In addition to the State DOE, the Johor local council responsible for
the Forest City site (MPJBT—the Middle Johor Bahru Municipal Council)
played an important role in approving the project. 268 Hana Badriah, a
planner at IRDA, suspected that political involvement may have shifted
emphasis toward development and tended to neglect environmental
regulations: “The officers on the local council do the best that they can to
ensure that projects comply with whatever is required. But sometimes they
will provide technical advice to higher levels and it is ignored by those who
are actually making decisions.“ 269 Either through the involvement of the
Sultan or pressure to attract investment, the priorities evolved up the chain
of command. While officers generally provide sound advice, Badriah
suggested that “there may be some political interests in the top
management.”270 Furthermore, Badriah noted that environmental
protection was not a priority for councilors: “They might be aware of the
environment, but for them most are focused on the economic part of
development. Environmental conservation is not directly incorporated into
their practices.” 271
Land matters in Malaysia fall under the authority of individual
states. 272 This may have inhibited effective federal action to block the
Forest City project or otherwise exert comprehensive management or
planning controls over the area. In the United States, for example, the
large amount of federal land, especially in the West, enables the U.S.
president to easily declare new protected areas as national monuments. In
Malaysia, by contrast, the federal marine parks department had been
working for some time, unsuccessfully, to designate a marine park around
the Merambong Shoal. 273 UTM hydrology professor Dr. Maketab attributed
the increase in reclamation to this system of state authority over land. It
makes it “very difficult to maintain a coordinated national policy on land
use that is balanced and controlled. I think this is one of the main follies of
environmental management here—that land is a state matter.” 274
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IRDA planner Hana Badriah concurred, noting that in Johor, “the

water is seen as part of the land, which is a state matter.” 275 As a result,
the state could unilaterally grant land to CGPV for reclamation, bypassing
federal approval and scrutiny until the government in Putrajaya intervened
on environmental grounds.
More broadly, the institutional situation in Johor and at the federal
government almost certainly contributed to CGPV’s initial missteps with
Forest City. UTM hydrology professor Dr. Maketab Muhamad paints a
disquieting portrait of Johor politics, in which cronyism and royal
interference are common. 276 Choo Chee Kwang, a marine researcher,
was “blacklisted” because he “stepped on some toes” with his advocacy
work trying to protect Merambong Shoal. An associate in line to become
head of the Johor DOE was effectively exiled for “stopping a barge of
sand.” Dr. Maketab claims there are many “sycophants, people who
always follow the Sultan.” The mentality among high-ranking officials is “if I
have the power, I will push this through.” 277

The role of Country Garden and associated actors

Multiple individuals interviewed for this thesis hesitated to blame
Country Garden directly for damage to the seagrass and other
environmental harms. Lena Wong noted that “Country Garden claims they
knew nothing [about the seagrass], but really it’s not their responsibility.”
While it seems reasonable that Country Garden would learn about the
area where it planned to develop, regulations and plans are ultimately in
place to safeguard against such ignorance. 278 Bakhtiar Jaffar agreed,
noting that “the company is not primarily at fault. The local authorities are
the primary issue for allowing everything to proceed without adequate
assessment. The company must deal with these authorities, so the blame
is mostly on them.”279
Serina Rahman, in turn, pointed to the local Malaysian partners
who should have known and understood requirements and local
conditions: “the issue is they are foreign and they have local parties
insisting ‘it’s ok’…in [public] presentations it is the locals who are pushing
this through.” 280 Having received such local assurances, Country Garden
proceeded with the project.
Dr. Serina Rahman also paints a picture of the Port of Tanjung
Pelepas (PTP) as a complicit party. The port formally protested the Forest
City reclamation in a focus group discussion, arguing that their federal
concession gave them rights to expand operations in the area where
Forest City is sited. Yet behind this contentious public stance, Dr. Serina
Rahman suggests that PTP used the “Country Garden chaos” as a form of
cover for their own expansion and associated environmental impacts. 281
Before Forest City, PTP had been the object of residents’ contempt for

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disrupting the marine environment, interfering with the fishermen’s

activities and failing to deliver on promises of jobs. 282 CGPV is clearing
large tracts of land on the mainland in Tanjung Kupang for worker housing
and temporary facilities to support the development. Most of that land is
currently owned by PTP. Once the development is complete, Dr. Rahman
suggests, PTP will resume control, free to develop it into warehouses and
more port facilities. Forest City therefore fits into their long-term expansion
strategy, bearing the brunt of public controversy while helping them
achieve their ultimate objectives. 283
The DEIA consultants, Dr. Nik and Associates, were under their
own form of pressure. Dr. Nik, whom Professor Maketab claimed to know
personally, did not want the contract, but had little choice, as the firm’s
future business depended on environmental consulting for large Johor
projects that need DOE approval. Maketab further claimed that the Forest
City DEIA was initially rejected because it “wasn’t telling the truth” and
lacked detail on predicted impacts. 284 At the federal level, marine
researcher Dr. Lena Wong cited a general lack of capacity at the DOE in
Putrajaya, claiming that they relied on her team of university researchers
to keep them updated on the status of Forest City. “They are dependent
on us,” she noted. 285

Evaluating megaprojects through Forest

City
The case of Forest City has a number of important implications for
megaprojects in East Asia and beyond. Fundamentally, it demonstrates
that non-compliance with regulation can prove incredibly expensive, both
monetarily and in terms of reputation. Given the involvement of Singapore,
the Forest City case demonstrates the limits of influence and
“exceptionality.” It highlights the value and importance of consultations
and community engagement. Acting on local knowledge and greater
compliance could have saved Country Garden both time and money.
Forest City reveals that environmental considerations are not mere
obligations, but valuable possibilities in their own right. Civic engagement
may also pay dividends in political legitimacy that could have broad
implications for the long-term success of the project.
The failure of CGPV to consult stakeholders and engage
meaningfully with local plans and regulations resulted proved immensely
expensive for the company. Once the federal DOE had issued a stop work
order in June 2014, equipment and workers were idle, costing upwards of
RM 6 million a month. 286 The federal DOE then mandated expensive
mitigation measures for work already underway. In particular, CGPV was
compelled to remove sand it had deposited on the Merambong Shoal

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seagrass bed. Pulling together the DEIA at short notice cost some RM3
million. 287 CGPV was saddled with an extensive project redesign to
accommodate a valuable seagrass bed, and to reduce its overall impacts
on the environment. The project was scaled down twice, reducing its gross
development value by RM150 billion. 288 Large-scale reclamation
associated with Forest City also hastened the passage of a new (and
retroactive) tax on reclaimed land, designed to support a compensation
fund for fishermen who stood to lose their livelihoods. 289 Quick
calculations suggest that CGPV contributed at least RM45 million.
Forest City also suffered the intangible costs of damage to its public
image. Media coverage frequently painted an unfavorable portrait of the
developer as out-of-touch, or acting above the law. While the extent of the
impact is unclear, the controversy likely tarnished Forest City’s brand. This
potentially had an important, though unknowable, impact on future sales.
CGPV launched extensive reclamation works in close proximity to the
international border, in a region where reclamation is politically sensitive.
Consequently, they alarmed the Singapore government and threatened an
international dispute. Given that CGPV’s long-term strategy targets
Singapore buyers, their approach seems especially wrongheaded. During
one session of Singapore’s parliament, an MP from Nee Soon, Dr. Lee
Bee Wah, even asked the foreign minister to “urge Singaporeans not to
buy any projects at this Forest City project.” 290
The environmental destruction associated with early reclamation
efforts appears even more senseless, given Country Garden’s subsequent
reaction. Depositing sand on the seagrass appears to have been a
mistake—a product of ignorance—than an act of malice. Taking what
Country Garden says at face value, Dr. Serina Rahman believes they
were entirely unaware of the value of the seagrass habitat. The
representatives were surprised by the diversity of marine life it supported,
and expressed genuine remorse for burying several hectares of
Merabmong Shoal. Dr. Rahman thought that “they are trying to listen and
take public comment seriously. They seem to want to do something to
make up for how much they have screwed up already.” 291 An executive at
Country Garden, Dr. Runze Yu, expressed deep ambivalence about the
development process and its environmental impacts. Having worked
previously for the World Bank, he reported “I’m always asking myself,
what is the right rate of development? Because there is just no zero-
impact solution.”292 He clarified that CGPV’s position: “we don’t want the
mangroves along the coastline to disappear…we want the seahorses to
be there. We want to protect the local environment at a maximum.”293
In retrospect, even the smallest consideration given to local
residents or existing plans could have saved CGPV many subsequent
complications. Consulting any fisherman or planning professional would
have revealed both the presence and value of the seagrass bed and
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highlighted the political sensitivity surrounding land reclamation in the

Straits. In its marketing, Forest City emphasizes the natural setting of the
site, highlighting “seagrass and mangrove conservation.” 294 The developer
has expressed intentions to make the seagrass bed a focal point of the
project. Ironically, CGPV’s initial actions undermined the very natural
resources it intended to market. Far from being an unnecessary obstacle,
conducting an EIA before beginning the project would have revealed
strategies to minimize damage to the natural environment and preserve
key resources, in a way that might have enhanced the project’s value
proposition.
This points to an important lesson regarding megaprojects:
exceptionality does not operate across all scales. The Sultan may have
the power to influence approvals in Johor, and potentially even at the
national level, but his influence does not and did not extend over
Singapore. Once Singapore’s prime minister became involved, it appears
that the Malaysian government had no choice but to enforce the relevant
environmental regulations and halt work on the project. By relying
exclusively on their local partners, Country Garden confronted the limits to
exceptionality. This suggests that in many cases, there are overlapping
structures of control or influence, some of which may not be immediately
evident.
Although physically an archipelago, Forest City is dependent on a
web of infrastructure that extends well beyond the limits of the project. It
will require immense inputs of water and electricity and generate
tremendous quantities of waste. 295 There is considerable risk around the
provisioning of such utilities, especially when resources are scarce. A true
commitment to sustainability would reduce these dependencies; for
example, the development could rely on fewer automobiles and consume
less energy. It appears doubtful, however, that Country Garden’s reactive
planning approach will serve these ends.
At the same time, proper engagement with the community is a key
component of managing this risk. It was only after reclamation was well
underway that CGPV was forced into an attitude of greater social
responsibility. Consulting local residents would have given the project a
sense of legitimacy that may prove crucial if, for example, water shortages
force local authorities to decide between providing water for Malay
communities or for an international enclave populated with outsiders.
It is evident that Forest City engages with the language of
globalization. The project is marketed outwards towards an elite
international clientele. Its architecture and style bear little resemblance to
the forms of its surroundings. Its amenities are world-class, and yet in
many respects generic. There are several other projects in Johor—some a
handful of kilometers away—that market to a similar affluent clientele with
their own “world-class” amenities and services. Promotional materials from
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Forest City and Guangzhou R&F’s Princess Cove project both have slick
renderings of glassy skyscrapers and images of busy young executives.
Country Garden may struggle to distinguish itself in a field crowded with a
number of smaller, but still similar, competitors.

Lessons
Country Garden has faced considerable obstacles in implementing
Forest City. The development environment in Johor is quite unlike that in
China, involving as it does more agencies, authorities, and political
complexities. At the same time, they probably relied too heavily on the
Sultan and local partners. Initial plans were incompatible with the site.
Each of these is a lesson, an opportunity to become a more sensitive and
responsible developer.
Forest City represents a commitment that will play out over many
decades, with tremendous responsibilities. Likely to involve over thirty
years of construction, 296 the project will require the company to maintain
and manage the development, while negotiating such issues as urban
governance, utilities, and service provision. Forest City is unlike the
townships that Country Garden has developed in the past; it is conceived
as a self-contained city with a central business district, industry, and a
strong commercial base. 297 If Country Garden is to realize this vision, it
will have to evolve considerably as a company. The outcome will set an
important precedent for Chinese development abroad.

Lessons for Forest City

Having made their name in mainland China, it seems that Country
Garden was unprepared for the very different development environment in
Malaysia. Sasaki’s Michael Grove noted that “being Country Garden’s first
development outside of the mainland, there wasn’t a lot of understanding
of all the obstacles they might face during the process.”298 Dr. Jeffrey Yee,
an executive at the rival Chinese developer Guangzhou R&F, offered a
similar opinion: “Developing a whole township in China is different. It’s all
planned ahead of time by the government.”
In China, Yee said, state planners would have determined basic
specifications and arranged infrastructure to support those specifications.
He explained how his own company was facing “the new experience of
provisioning all our own infrastructure. It’s really abnormal for R&F,
compared to what they know.” 299 Dr. Yee did not believe Country Garden
adequately considered this before launching Forest City. Confirming his
suspicions, Dr. Runze Yu of Country Garden acknowledged the
comparative difficulty of working in Malaysia. Receiving zoning approval
required “go[ing] through I think thirteen different agencies. It’s incredible.”
He stressed that “we are not really criticizing the system or the
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government…it’s just the procedure you have to go through.” 300 Dr. Yu

added that they had to challenge many existing planning regulations in
order to build their vision—a process that added time and complexity.
Country Garden likely placed too much faith in its local Malaysian
partners and connections with the Sultan. While the Sultan of Johor enjoys
immense influence, there are clear limits to his power. Dr. Serina Rahman
believes that Country Garden should not have relied so heavily on either
the Sultan or other Malaysian partners. 301 For Michael Grove, “the mistake
was they thought they had the Sultan as this great political connection and
therefore they could just move ahead without barrier.” Even though the
minority stakeholder was the Sultan himself, and “[Country Garden]
thought they might have a lot of political capital,” Grove believes that they
misunderstood the political climate of Malaysia as a relatively active
democracy. 302 They also failed to understand the implications of working
in such close proximity to Singapore, given the often tense relations
between the two countries, and their history of disputes over reclamation.
A deft handling of cross-border issues was essential, especially since
Country Garden sought to attract buyers from Singapore and have Forest
City designated a “passport-free zone.” 303
Country Garden’s interactions with IRDA suggest that they were
unprepared for the scope of the project they envisioned. IRDA became
involved as part of the DEIA process, helping set the terms of reference
for the report and commenting on drafts. Planner Hana Badriah described
her sense of meetings with Country Garden:

From the start, we got the impression that Country Garden

really didn’t know what they wanted to do, based on how
minimal their initial plans were and the kinds of questions
they were asking. They just took what we proposed for them.
They took the green city idea [though not vertical greening]
from us, for example. They didn’t really have much of a plan.
They were asking about our promoted sectors and seeking
to fit their development with those. 304

The developer at least appears to have been responsive to IRDA’s

input, and desired to incorporate Forest City into their various master
plans, notwithstanding their utter lack of compliance with the existing
documents. A number of times, they reportedly reworded sections of the
DEIA to take into account IRDA’s concerns. 305
Country Garden’s initial plan for Forest City was developed
internally, and was extremely aggressive. It proposed a massive amount
of fill in a single landmass without much consideration for local hydrology.
The plan ignored environmental impacts. Michael Grove of Sasaki
implicates this insensitivity in the project’s initial missteps: “it didn’t take
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into consideration any environmental issues at all, and that’s when there
was a lot of pushback.”306
As a developer with global ambitions, Country Garden is planning
projects in many places with environmental and planning regulations far
stricter than those in Malaysia. The recent launch of Ryde Garden, an
830-unit development near Sydney, is an early example. 307 According to
Michael Grove, working in foreign settings is “still something they are still
trying to navigate through and understand.” Accordingly, even though
Ryde Garden is miniscule compared to Forest City, it has been delayed
due to difficulties in working with the Australian town planning system. 308
These difficulties get to the heart of the broader theme of Chinese
developers expanding overseas. As they aspire to launch projects in
countries with a very different developer process than their own, there will
inevitably be an awkward stage of learning and evolving.
By prioritizing its connection with the environment, Forest City could
distinguish itself as a locally rooted megaproject. It could consider the
edge conditions of the islands, and cultivate successful mangrove
habitats. It could incorporate the natural environmental more centrally into
the project, far beyond the veneer of “vertical greening.” And, as noted,
there might be substantial economic value in cultivating a sense of place,
or pursuing a kind of authenticity, when responding to surroundings.

Broader implications of Forest City

While many Chinese developers have faced significant difficulties
abroad, a handful of examples seem to point the way forward. Some
Chinese developers have shown great tact and sensitivity in their
overseas projects. The Chinese consortium behind the Baltic Pearl in St.
Petersburg, including the Shanghai Industrial Investment Company, is a
case in point. They managed to navigate the difficult political environment
between China and Russia while simultaneously engaging both municipal
and state interests. 309
While not without its critics, Greenland Group has launched
numerous projects in the West, primarily through partnerships with local
developers. 310 While an open and transparent approach to development
may constrain near-term profits, it generally reduces the barriers to market
entry and limits risk. In Malaysia, Country Garden did hire local Malaysian
staff, but remains the sole developer of Forest City. Along similar lines,
while Chinese developers are accustomed to working at immense scales,
it may be prudent to begin with smaller ventures abroad. Country Garden
seems to have heeded this lesson with its first foray into Australia.
For Country Garden, Forest City represents a tremendous long-
term commitment, where failure could be disastrous for the company. It is
not a project they can simply develop and unload quickly, but one that will

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require continuous shepherding over the course of its thirty-year

development timeline and beyond. In working with Country Garden,
Michael Grove acknowledged that “because of the scale and the timeline
of the project there’s a lot of understanding that they have to do it right.” 311
Even after they have invested the reported RM 176 billion (around US $43
billion) 312 necessary to achieve Country Garden’s vision, they will bear the
responsibility of owning, maintaining, and upgrading the project. Country
Garden is only just beginning to struggle with challenges of urban
governance—whether the project will have its own local council, how
urban utilities will be paid for, and other equally pressing issues. While
recognizing the immense challenges involved, Michael Grove is optimistic
that “they are going to want to continue to learn from their mistakes, and
they are going to continue to improve things as they go.” 313
Country Garden’s initial emphasis with Forest City has been on
quickly delivering a product they can market to mainland Chinese buyers
and thereby secure enough commitments to maintain their financing.
Eventually, however, Country Garden will need to broaden its strategy to
appeal not just to Chinese investors, but also to an international clientele
interested in living in the project long-term. 314 Country Garden will have to
build the amenities and cultivate the business and employment
opportunities that will enable people to live successfully within Forest City.
Michael Grove of Sasaki believes that, in the long-term, “the reality is that
they’re going to have to be more robust in their construction of the public
realm in order to attract more of the market base that they’re hoping to
achieve.” 315
In pursuit of their long-term vision for the project as a self-
contained, new global city with its own CBD, creative industries, research
and development activities, and an overall “world class” 316 quality, Country
Garden is making a tremendous commitment. It has people “staking their
careers on being in Malaysia and the success of the project.”317 This will
require a fundamental re-orientation in the company’s business model and
thinking. Unlike Danga Bay—which is much closer to their mainland
Chinese projects as a second-home investment opportunity318—Forest
City aims to be its own, integrated community that leverages close
connections with Singapore. Commenting on his interactions with Country
Garden, Michael Grove explained:

There’s a realization that they need to understand the local

climate, the political climate, the approvals process,
everything from community engagement through
environmentalist groups and activists. So there’s a desire on
their part to be more immersive. I’m not sure they’ve
achieved it yet, and I don’t think they will in the short-term, I
think this will take a long time as they hire more specialists,
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and bring people on board that are actually insiders from

Malaysia and not outsiders from China. 319

Ultimately, the Forest City project has implications not just for
Johor, but nationally in Malaysia, Singapore, and the broader Southeast
Asian region. As an almost unbelievably ambitious flagship project, its
success or failure could signal the future of development in the region.
Because other Chinese developers are no doubt monitoring Forest City’s
example, the project has major implications for overseas Chinese
development and future megaprojects in general. Already, Forest City
conveys important lessons for developers: addressing the concerns of
neighbor nations, not relying on connections with local power players
(especially if the goal is to circumvent local regulations), being open to
environmental regulations and EIAs, and willingness to engage the federal
government in addition to the state, among others. Chinese developers
are moving past the stage of pursuing projects for immediate profit and
transitioning to a stage of exerting “a larger impact on the world, and
[being] seen as credible players in the marketplace.” To succeed, Country
Garden will need to look beyond “low-hanging fruit,” 320 and embrace
rigorous global standards.

Conclusion
In their comprehensive study of megaprojects, Altshauer and
Luberoff argue that “efforts to realize large-scale investment projects often
provide an unusually revealing window on patterns of influence in urban
development politics.”321
For Johor, the Forest City development provides a powerful lens
through which to understand such patterns of influence. It highlights the
power of the Sultan and his integral role in the development of Johor. At
the same time, it exposes the limits of his influence as the developer
confronted the interests of Singapore and the Malaysian federal
government. Forest City speaks to the growing role of Chinese developers
abroad, and also to the great challenges they face in negotiating
unfamiliar contexts. It exposes a disregard for the natural environment and
reveals a subsequent effort to reduce environmental impacts. More
broadly, Forest City reveals significant weaknesses in the functioning of
democracy and community engagement in Johor, and also spotlights
impediments to federal intervention.
At the same time, Forest City is bound up in complex patterns of
globalization. It is a Chinese-led project rooted in township developments
in Guangdong, sited in southern Malaysia, that will attempt to leverage
economic spillover from Singapore. Forest City bears the mark of an
international team of consultants, contains “world-class” facilities, and
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aims to attract an affluent, global clientele. It fits directly into a narrative of

mobile global capital, “competitive landscapes,” 322 and enclave urbanism
that orients itself outwards, away from local communities, customs, and
urban morphologies. As a self-proclaimed “model for future cities of the
world,” 323 it professes a totalizing vision of urban life that demands terra
nova—a true blank slate for its creation. As such, it stands in stark
contrast to the growing number of urbanists advocating the opposite
approach to development: that is, locally oriented, humanly scaled,
environmentally friendly, and sustainable projects that are endowed with
an architectural character that responds to the local setting and its
traditions.
Forest City remains in the embryonic stage of its development.
Nevertheless, it already holds important lessons for Chinese developers
operating overseas. The saga of Forest City is a kind of bildungsroman for
Country Garden, as it evolves from a Chinese township developer to a
global company, overseeing the construction and growth of a vast,
integrated new city. It is too soon to speculate over the success of the
project—but even if it falls short of its ambitions, it has established an
important precedent for Chinese developers. Its outcome will have broad
implications for Johor, the region, and beyond.

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Acknowledgments
I am first and foremost indebted to my advisor, Professor Larry
Susskind, for his guidance, support, and helpful feedback. He helped me
travel to Malaysia twice for fieldwork in support of this research. He called
upon his connections at high levels to help arrange interviews in
Singapore and Johor. In short, he has shepherded me through a journey
that began with a practicum in January 2015 and has culminated in this
thesis.
Much of the funding for this research came from the Malaysia
Sustainable Cities Program. Dr. Kelly Heber-Dunning has my sincerest
thanks for introducing me to Johor, connecting me to her network of
friends there, and teaching me to love mangroves. I am especially grateful
to Takeo Kuwabara for his assistance and friendship, both in Cambridge
and abroad. For coordinating and enabling the MIT-MSCP program,
Bettina Urcuioli deserves my respect and gratitude.
I also owe a great deal to Dr. Serina Rahman, who provided
immense assistance throughout my fieldwork in Malaysia. She helped
arrange interviews with fishermen and served as an interpreter. Through
Serina, I was also able to visit the Forest City reclamation site several
times to document its progress. Staff at IRDA, particularly Hana Badriah
and Maimunah Jaffar, likewise deserve particular thanks for hosting me at
the IRDA office during my first trip to Malaysia. They extended a warm
welcome and helped facilitate a number of further connections. Dr. Runze
Yu of Country Garden generously invited me to the Forest City global
press conference in Singapore. Many others in Johor made my time there
especially memorable.
I would like to acknowledge Libbie Cohn, who also conducted
research on Forest City as part of a separate collaboration. She helped
arrange valuable interviews, and provided essential translation assistance
for Chinese-language materials.
Finally, I am eternally grateful to my parents for their unwavering
encouragement, support, and love throughout my education. My father,
Dr. Robin B. Williams, provided insightful editorial feedback and guidance.
He continues to serve as a role model in my life.

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Appendix A: List of people interviewed

Name Title Affiliation Date
Abu Talib bin
Khamis Fisherman 8/17/2015
Bakhtiar Jaffar Kampong Pendas resident, SOS advisor SOS 8/1/2015
DAP (Democratic Action Party)
Cheo Yee How Assemblyman for Pengkalan Rinting DAP 1/20/2016
Cynthia Wong Singapore resident and environmentalist 8/4/2015
Professor, Department of Geography
Dr. Daniel Freiss (mangroves specialist) NUS 7/19/2015
Hana Badriah IRDA staff, Planning and Compliance IRDA 8/19/2015
Harun bin Awang Fisherman 8/15/2015
Dr. Jeffrey Yee Vice General Manager Guangzhou R&F 8/13/2015
Fisherman, contract work for Country
Lan Rahman Garden 8/16/2015
Professor, performs environmental
Lena Wong monitoring for FC UPM 8/1/2015
Maimunah Jaffar Director of Planning and Compliance, IRDA IRDA 7/14/2015
Dr. Maketab Professor, Water Quality and Water
Mohamed Quality Monitoring UTM 8/6/2015
Principal at Sasaki, Lead Designer for Forest
Michael Grove City Sasaki 12/2/2015
Michelle Lew IRDA staff, Planning and Compliance IRDA 9/6/2015
Dr. Mohd
Hamdan bin haji
Ahmad Professor, Architecture and Director of ISI UTM 7/27/2015
Ooi Boon Leong Secretary, Save our Seahorses SOS 8/19/2015
Dr. Runze Yu Regional Vice President at Country Garden Country Garden 1/16/2016
Dr. Serina
Rahman Director, Kelab Alami Kelab Alami 7/17/2015
Sharil [single
name] Fisherman 8/1/2015
Manager, Engineering and Sustainability
Veron Ng Div G-Energy 1/28/2016
Director, Johor branch of the Malaysia
Vincent Chow Nature Society MNS 8/12/2015

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EVALUATING MEGAPROJECTS: Joseph Marcel R. Williams
THE CASE OF FOREST CITY
IN JOHOR, MALAYSIA

Name Place Elapsed time

Abu Talib bin
Khamis Kg. Pendas Jetty 45 minutes
Bakhtiar Jaffar Bakhtiar Jaffar's residence, Kg. Pendas 140 minutes
Cheo Yee How DAP Johor Office 45 minutes
Cynthia Wong Gelang Petah 20 minutes
Dr. Daniel Freiss Starbucks, downtown Singapore 60 minutes
Hana Badhria IRDA office 90 minutes
Harun bin Awang Kg. Pendas Jetty 40 minutes
Dr. Jeffrey Yee R&F Development Sdn Bhd 90 minutes
Lan Rahman Mamak, Gelang Petah 50 minutes
Lena Wong Bakhtiar Jaffar's residence, Kg. Pendas 140 minutes
45 and ~90
Maimunah Jaffar IRDA office minutes
Dr. Maketab
Mohamed Prof Maketab's office, UTM 90 minutes
Michael Grove Remote [Conducted by Libbie] 40 minutes
Michelle Lew Remote N/A
Dr. Mohd
Hamdan bin haji
Ahmad Institute Sultan Iskandar, UTM 45 minutes
Ooi Boon Leong Remote N/A
Dr. Runze Yu Chakra Restaurant, Johor Bahru 60 minutes
Dr. Serina
Rahman JB City Square mall 120 minutes
Sharil [single
name] Serina Rahman's residence 20 minutes
Veron Ng G-Energy Office, Singapore 40 minutes
Vincent Chow Auntie Lim' s Café, Taman Molek 90 minutes

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EVALUATING MEGAPROJECTS: Joseph Marcel R. Williams
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IN JOHOR, MALAYSIA

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IN JOHOR, MALAYSIA

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THE CASE OF FOREST CITY
IN JOHOR, MALAYSIA

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THE CASE OF FOREST CITY
IN JOHOR, MALAYSIA

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[150] Shaua Fui, Chen. “Forest City resumes but GDV shrinks
25% to RM450b” The Edge Markets, Mar. 20, 2015.
[151] Sheehan, Matt. “Greenland Group looking to offload stake
in $5 bil Brooklyn project.” Mingtiandi, Apr. 17, 2016.
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[152] “Singapore wants more information on Johor project:

MFA.” The Star, Jun. 22, 2014.
[153] Smith, Michael P. Transnational Urbanism: Locating
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[154] Snoj, Jure. “Population of Qatar by Nationality.” BQ
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[155] Sock Ken, Low. “DEIA report lacks scientific data, says
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[156] “Somerset Puteri Harbour Nusajaya: Overview.” Somerset
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[157] Sparke, Matthew, James D. Sidaway, Tim Bunnell, and
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[158] Stone, Diane. "Transfer agents and global networks in the
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[159] “Such quantities of sand.” The Economist, Feb. 28, 2015.
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[161] Swyngedouw, Erik, Frank Moulaert, and Arantxa
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Antipode 34, no. 3 (2002): 542-577.
[162] Tan, Ck. “Malaysia-Singapore commute a daily grind.”
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[163] Taylor, Paige. “Malaysian royal pays $8.5m for a little ray
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[164] Teoh, Shannon. “Johor Sultan calls for restoration of
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[165] “Transcript of Second Minister for Foreign Affairs Grace

Fu’s Reply to the Parliamentary Question, 19 January
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[166] “Transcript of Senior Minister of State for Foreign Affairs
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[168] United Nations University—International Network on
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[169] Valuation and Property Services Department Ministry of

Finance Malaysia. “Land Alienation”
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[176] Watts, Jake Maxwell and Fung, Esther. “Ambitious
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[177] Weinberg, Cory. “One of the world’s biggest developers
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[178] Wong Chun Wai and Nelson Benjamin. “Sultan of Johor
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[182] Zain al-'Abidin Muhriz, Tunku. Abiding Times: An Insight
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[184] Zheng, Anjie. “Country Garden Holdings 2015 Net Profit

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[186] Zulfakar, Mergawati. “Connecting routes, improving ties.”
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Notes
1 Several sources use this concept, including Matthew Sparke, James D.
Sidaway, Tim Bunnell, and Carl Grundy-Warr, "Triangulating the
Borderless World: Geographies of Power in the Indonesia-Malaysia-
Singapore Growth Triangle," Transactions of the Institute of British
Geographers 29, no. 4 (2004): 485-498.
2 Alan A. Altshuler and David E. Luberoff. Mega-projects: The Changing

Politics of Urban Public Investment (Washington, DC: Brookings Institution

Press, 2003), 4.
3 Ng Bei Shan, “Country Garden, KPRJ plan massive reclamation

development,” The Star, Mar. 19, 2014.

4 Anita Gabriel, “Forest City: Healthy foreign investment or blight on

Iskandar,” The Business Times, Jan. 30, 2015.

5 See Iskandar Regional Development Authority. “Shoreline Management

Plan Blueprint for Iskandar Malaysia,” (2011), 21-25.

6 Dr. Serina Rahman, interview by author, Jul. 17, 2015; and Cheo Yee

How, interview by author, Jan. 20, 2016.

7 The Sultan himself actually held 21 percent directly. Other portions were

held by his close associate Daing A Malek. See Nigel Aw, “The case of
Forest City and the Johor sultan,” Malaysiakini, Jul. 14, 2014.
8 A letter from the Johor DOE is included in the DEIA Vol. 5 Sec. B4. For a

more in-depth discussion of regulations, see Chapter IV “Lack of

Compliance with Existing Regulations”
9 Reme Ahmad and Rennie Whang, “Housing glut worries over Johor’s

mega projects,” The Straits Times, Feb. 23, 2015.

10 Forest City DEIA Vol. 1 Executive Summary, and Benjamin Nelson,

“Proposed Johor multi-billion-ringgit Forest City Project scaled down,” The

Star, Jan. 15, 2015.
11 Nigel Aw, “Johor Sultan ‘initiated’ Forest City mega project,”

Malaysiakini, Mar. 19, 2015.

12 Danga Bay was Country Garden’s first overseas venture in Malaysia,

located closer to region’s central business district in Johor Bahru. The

project resembles more closely Country Garden’s township developments
in mainland China. It consists of a parking podium with high-density
residential towers and ground-level retail.
13 Nigel Aw, “Johor sultan ‘initiated’ Forest City mega project,”

Malaysiakini, Mar. 19, 2015.

14 Ibid.
15 Dr. Maketab Muhamad, interview by author, Aug. 6, 2015.
16 Chen Shaua Fui, “Forest City resumes but GDV shrinks 25% to

RM450b,” The Edge Markets, Mar. 20, 2015.

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17 Ng Bei Shan, “China-Malaysia developers plan 5,000-acre man-made

island off Johor,” The Star, Jun. 16, 2014.
18 Ck Tan, “Malaysia-Singapore commute a daily grind,” Nikkei Asian

Review, Mar. 12, 2015.

19 Jake Maxwell Watts and Esther Fung, “Ambitious Chinese Developers

Plan Cities Abroad From Ground Up,” The Wall Street Journal, Mar. 1,
2016.
20 There are ongoing disputes over the sovereignty of small islands and

reefs in the South China Sea. China continues an active program of land
reclamation in a bid to claim control of the islands, which it argues also
entails rights to territorial waters. Others suspect a military objective. See
“Such quantities of sand,” The Economist, Feb. 28, 2015.
21 Ng Bei Shan, “Stormy property landscape,” The Star, Jun. 21, 2014.
22 Marissa Lee, “Iskandar developers: China buyers will mop up excess

units,” The Straits Times, Feb. 23, 2015.

23 Chen Lixiong and Li Huiling, “Chinese Developers’ Projects in Malaysia

Run into Series of Snags,” Caixin Online, Nov. 13, 2014.

24 Dr. Jeffrey Yee, interview by author, Aug. 13, 2015.
25 Hafiz Noor Shams, “Property developers face glut in Malaysia’

Iskandar,” The Financial Times, May 22, 2015.

26 Ibid.
27 “Johor Sultan says Forest City property project will boost state

economy,” The Malay Mail Online, Mar. 18, 2015.

28 Forest City DEIA Vol. 5 Sec. B6
29 Cheo Yee How, “Disagreement with the proposed Forest City project,”

Democratic Action Party Malaysia, Sep. 22, 2014; and Cheo Yee How,
interview by author, Jan. 20, 2016.
30 Eileen Ng, “Johor fishermen’s income halved due to reclamation work,

says Ismail Sabri,” The Malaysian Insider, Mar. 25, 2015; Cheo Yee How,
interview by author, Jan. 20, 2016.
31 “Forest City developer to submit environment report on Johor

reclamation work,” The Star, Jun. 28, 2014.

32 Boo Cheng Hau, “JOPREC’s Review on Forest City DEIA,” Dr. Boo

Cheng Hau’s Trilingual Blog, Feb. 27, 2015.

http://drboochenghau.blogspot.com/.
33 Eileen Ng, “Johor fishermen’s.”
34 Rahmah Ghazali, “Malaysia in discussion with Singapore over land

reclamation work in Johor,” The Star, Jun. 24, 2014. See also “Transcript
of Second Minister for Foreign Affairs Grace Fu’s Reply to the
Parliamentary Questions,” MFA Press Release, Jan. 19, 2015.
35 “Transcript of Senior Minister of State for Foreign Affairs Masagos

Zulkfli’s reply to Parliamentary Questions.”

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36 In that case, the positions essentially reversed, as Malaysia protested

Singapore’s reclamation work at Tuas and Pulau Teekong. Attempts at a
negotiated resolution broke down after Malaysia demanded that
Singapore suspend reclamation as a precondition of any subsequent
talks. Singapore refused, and Malaysia responded by bringing its case to
the International Tribunal for the Law of the Sea (ITLOS). The court
eventually compelled Malaysia and Singapore to cooperate and resolve
their differences on the basis of an objective study by independent
experts. See Chandrasekhara Rao, “Separate Opinion,” ITLOS Case No.
12.
37 “Transcript of Senior Minister of State for Foreign Affairs Masagos

Zulkfli’s reply to Parliamentary Questions,” MFA Press Release, Jan. 19,

2015.
38 Ibid. See also Mergawati Zulfakar, “Connecting routes, improving ties,”

The Star, May 4, 2015.

39 “Hope,” Country Garden Promotional Video distributed to attendees of

Forest City Global press conference, Singapore, Jan. 21, 2016.

40 Dr. Runze Yu, interview by author, Jan. 16, 2016.
41 Nigel Aw, “The case of Forest City and the Johor sultan,” Malaysiakini,

Jul. 14, 2014.

42 “About Property Developer,” iProperty.com, accessed May 4, 2016.
43 Ooi Boon Leong, email message to author, Aug. 19, 2015. See also

Fernando Fong, “DEIA study must engage locals, says environmentalist,”

The Rakyat Post, Sep. 25, 2014.
44 Vincent Chow, interview by author, Aug. 12, 2015.
45 Iskandar Regional Development Authority, “Shoreline Management Plan

Blueprint for Iskandar Malaysia,” 2011.

46 “Comprehensive Development Plan for South Johor Economic Region,”

Khazanah Nasional, Nov. 2006.

47 “Building True Value: The Khazanah Report 2014,” Khazanah Nasional,

May 2015.
48 See Country Garden, “Sea Oasis City of the Future” [translated from

Chinese], Forest City promotional brochure, Jan. 2016; and Country

Garden, “Green Capital” [translated from Chinese], Forest City
promotional brochure, Jan. 2016.
49 Nicole Kobie, “Malaysia’s city of the future is an uncanny valley,” Wired,

Mar. 22, 2016.

50 Ibid.
51 Medilyn Manibo, “Malaysia’s Forest City primed for green development,”

Eco-Business, Mar. 11, 2016.

52 See, for example, Swyngedouw et al., "Neoliberal urbanization in

Europe;” and Altschuler and Luberoff, Mega-projects.

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53 Iskandar Regional Development Authority, “Shoreline Management Plan

Blueprint for Iskandar Malaysia” (2011), 21.
54 Swyngedouw et al., "Neoliberal urbanization in Europe.”
55 Iskandar Regional Development Authority, “Shoreline Management Plan

Blueprint,” 21.
56 Ibid.
57 Iskandar Regional Development Authority, “Integrated Land Use

Blueprint for Iskandar Malaysia” (2011), 18.

58 Iskandar Regional Development Authority, “Shoreline Management Plan

Blueprint,” 22.
59 Ibid., 23
60 “Comprehensive Development Plan for South Johor Economic Region,”

Khazanah Nasional (Nov. 2006), 11-16.

61 “Malaysia National Physical Plan—2.” Federal Department of Town and

Country Planning, Ministry of Housing and Local Government, Aug. 13,

2010.
62 “Comprehensive Development Plan for South Johor Economic Region,”

11-17.
63 Forest City DEIA Vol. 5 Sec. C, 5.
64 Datuk Amar Stephen K.T. Yong, “Environmental Quality (Prescribed

Activities) (Environmental Impact Assessment) Order 1987,” Sep. 30,

1987. http://www.doe.gov.my/eia/wp-
content/uploads/2012/03/Environmental-Quality-Prescribed-Activities.pdf
65 “Land reclamation project linked to royalty set to ruffle Malaysia-

Singapore ties, says report,” The Malaysian Insider, May 30, 2014.
66 Forest City DEIA Vol. 5 Sec. C, 23
67 Forest City DEIA Vol. 1 Executive Summary, 3
68 Malaysian National Marine Department, Southern Region port circulars,

2014.
69 Malaysian National Marine Department, Southern Region port circular

32, 2015.
70 Letter from the Johor DOE is included in the DEIA Vol. 5 Sec. B4.
71 Maisarah Makmor and Zulhabri Ismail, "A comparative study on EIA

process in Malaysia, West Australia, New Zealand and Canada," Jurnal

Teknologi 70, no. 1 (2014), 17.
72 “Environmental Site Assessment Approved for Altech’s Malaysian HPA

Plant,” Altech Chemicals, Jun. 19, 2015.

73 The plot, PTD 4102, cut directly across Merambong shoal, the largest

seagrass bed in Peninsular Malaysia—something that should have been

immediately evident to staff at the Johor DOE.
74 Forest City DEIA executive summary, 2
75 Hana Badriah, interview by author, Aug. 19, 2015.
76 Serina Rahman, interview by author, Jun. 17, 2015.

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77 Forest City DEIA Vol. 5 Sec B.6, 24

78 Serina Rahman, interview by author, Jun. 17, 2015; Cheo Yee How,
interview by author, Jan. 20, 2016.
79 Ibid.
80 Jennifer Gomez, “No EIA, but Johor coastal reclamation project already

underway, say sources,” The Malaysian Insider, Jun. 23, 2014.

81 “Forest City developer to submit environment report on Johor

reclamation work,” The Star, Jun. 28, 2014.

82 “Reclamation work at Johor Straits only involves 49 acres, no EIA report

needed,” The Star, Jun 23 2014.

83 Nelson Benjamin and Kathleen Ann Kili, “Land Reclamation works for

project will not affect environment.” The Star, Jun. 21, 2014.
84 Forest City DEIA Executive Summary, 3
85 Forest City DEIA Vol. 5 Sec. B.6, 7
86 Nigel Aw, “The case of Forest City and the Johor sultan,” Malaysiakini,

Jul. 14, 2014.

87 Appendix 2 Environmental Quality (Prescribed Activities)

(Environmental Impact Assessment) Order 1987

88 E.g. Forest City DEIA Vol. 5 Sec. C, 8.
89 Forest City DEIA Vol. 5 Sec. B.6, 9.
90 Abu Talib bin Khamis, interview by author, Aug. 17, 2015.
91 See, for example, Altshuler and Luberoff, Mega-projects; Kennedy,

"Large-Scale Urban Planning.”

92 Teoh, Shannon. “Johor Sultan calls for restoration of monarchs’

powers.” The Straits Times, May 9, 2016.

93 Ibid
94 Manathir Mohamad, “Dr M: Foreigners profited when sultans reigned

supreme,” Portalkini, Jun. 9, 2014.

95 See, for example, Tunku Zain al-'Abidin Muhriz, Abiding Times: An

Insight into the Minds of Malaysia's Thinking Youth (Singapore: Marshall

Cavendish Editions, 2010), 61.
96 “10 things to know about the Sultan of Johor,” The Straits Times, Mar.

20, 2015.
97 Serina Rahman, interview by author, Jul. 17, 2015.
98 Taylor, Paige. “Malaysian royal pays $8.5m for a little ray of Sunset.”

The Australian, May 21, 2015.

99 “Sultan of Johor buys ‘palace truck’” The Straits Times, Oct. 17, 2015.
100“Criticizing Malaysia’s Kings” Asia Sentinel, Jan. 27, 2010.
101 Khairul Khalid, “Is another constitutional crisis brewing in Johor?”

Kinibiz, Jun. 12, 2014.

102 Khairul Khalid, “Does Johor Sultan’s vape ban bypass due process?”

Kinibiz, Nov. 30, 2015.

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103 Shannon Teoh, “Johor Sultan calls for restoration of monarchs’

powers,” The Straits Times, May 9, 2016.
104 Khairul Khalid, “A gathering storm over Johor Sultan’s commercial

dealings,” Kinibiz, Jun. 10, 2014.

105 “It will be insane to tell investors not to come to Johor,” New Straits

Times, Mar. 22, 2015.

106 Ibid.
107 Khalid, “A gathering storm.”
108 Vanitha Nadaraj, “Is the Bubble Going to Burst in Iskandar or Is there a

Plan B,” The Establishment Post, Nov. 11, 2014.

109 Khalid, “A gathering storm.”
110 Khalid, “Is another constitutional crisis brewing in Johor?”
111 Khalid, “A gathering storm.”
112 Wong Chun Wai and Nelson Benjamin, “Sultan of Johor speaks his

mind,” The Star, Mar. 18, 2015.

113 “It will be insane to tell investors not to come to Johor.”
114 Ibid.
115 Ibid.
116 Wong and Benjamin, “Sultan of Johor speaks his mind.”
117 Nigel Aw, “Johor sultan ‘initiated’ Forest City mega project.”

Malaysiakini, Mar. 19, 2015.

118 Ng Bei Shan, “Country Garden, KPRJ plan massive reclamation

development for luxury homes,” The Star, Mar. 19, 2014.

119 Michael Grove, interview by Libbie Cohen, Dec. 2, 2015
120 Dr. Serina Rahman interview by author, Jul. 17, 2015.
121 Maimunah Jaffar, interview by author, Jul. 14, 2015.
122 “RM 290 billion profit over 30 years for controversial Johor project, says

report.” The Malaysian Insider, Sep. 15, 2014.

123 Valuation and Property Services Department Ministry of Finance

Malaysia, “Land Alienation.”

http://www.jpph.gov.my/v2/pdf/Land_Alienation.pdf.
124 Choong En Han, “Country Garden to launch maiden Malaysia project

with GDV of RM 10bil,” The Star, Jul. 29, 2013

125 Wong and Benjamin, “Sultan of Johor speaks his mind.”
126 “Bhd” stands for sendarian berhad, the Malaysian equivalent of “inc.”
127 Aw, “The case of Forest City and the Johor sultan.”
128 Kathy Fong and Ho Kay Tat. “Cover Story: Forest City poses no threat

to anyone, says ED,” The Edge Weekly, Oct. 23, 2014.

129 Nigel Aw, SOPA publishers award (Hong Kong).
130 Serina Rahman, interview by author, Jul. 17, 2015.
131 “Forest City—more clarity please.” The Star, Sep. 20, 2014.
132 Serina Rahman, interview by author, Jul. 17, 2015.

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133 Jennifer Gomez, “No EIA, but Johor coastal reclamation project already
underway, say sources,” The Malaysian Insider, Jun. 23, 2014.
134 Ibid.
135 Summer Zhen, “Country Garden’s ambition in Malaysia backed by

Johor’s royal family,” South China Morning Post, Feb. 11, 2016.
136 Gomez, “No EIA, but Johor coastal reclamation project already

underway.”
137 Nigel Aw,. “Of reclamation, sand and the royal company.” Malaysiakini,

Jul. 17, 2014.

138 Swyngedouw et al. (2003), 543., Warrack (1993), 5.
139 “Forest City – more clarity please.”
140 Bakhtiar Jaffar, interview by author, Aug. 1, 2015.
141 Abu Talib bin Khamis, interview by author, Aug. 17, 2015; Sharil

interview by author, Aug. 1, 2015; and Harun bin Awang, interview by

author, Aug. 15, 2015.
142 Abu Talib bin Khamis, interview by author, Aug. 17, 2015.
143 Bakhtiar Jaffar, interview by author, Aug. 1, 2015.
144 Cheo Yee How, interview by author, Jan. 20, 2016.
145 Ibid.
146 Cheo Yee How, “Disagreement with the proposed Forest City project,”

Democratic Action Party Malaysia, Sep. 22, 2014.

147 Forest City DEIA Vol. 2 Sec. 11, 18-25.
148 Bakhtiar Jaffar, interview by author, Aug. 1, 2015.
149 Sheridan Mahavera, “Johor villagers vent anger at mega reclamation

project,” The Malaysian Insider. Sep 2014.

150 Nandi, Roy K. “PR Lessons for Forest City.” The Sun Daily, Oct 2 2014
151 Forest City DEIA Vol. 5 Sec. C, 3.
152 Ibid.
153 Ibid., 22-24.
154 Ibid., 33.
155 Forest City DEIA Vol. 5 Sec. B6, 20.
156 Forest City DEIA Vol. 5 Sec. B6, 1.
157 Forest City DEIA Executive Summary, 3-5.
158 See, for example, John Glasson, Riki Therivel, and Andrew Chadwick,

Introduction to environmental impact assessment (New York: Routledge,

2013), 40.
159 Bent Flyvbjerg, “Design by Deception: The Politics of Megaproject

Approval," Harvard Design Magazine, no. 22 (Spring/Summer 2005): 50-

59.
160 Altschuler and Luberoff, Mega-projects, 215-220.
161 Shatkin, "The city and the bottom line,” 388.
162 Forest City DEIA Executive Summary, 5-7.

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163 “DOE approves entire controversial Johor Straits property project,” The
Malaysian Insider, Jan. 14, 2015.
164 “Land reclamation project linked to royalty set to ruffle Malaysia-

Singapore ties, says report,” The Malaysian Insider, May 30, 2014.
165 Charissa Yong, “KL has reassured Singapore over reclamation

concerns: MFA,” The Straits Times, Jul. 10, 2014.

166 “Singapore wants more information on Johor project: MFA,” The Star,

Jun. 22, 2014.

167 “Johor lawmakers say diplomatic row with Singapore possible over

manmade island,” The Straits Times, Dec. 23, 2014.

168 Estimates have varied quite widely, from 300,000 (DEIA Vol. 5 Sec.

B6, 23) to 700,000 (Kobie, “Malaysia’s city of the future is an uncanny

valley.” And Runze Yu, interview by author, Jan. 16, 2016.)
169 Hana Badriah, interview by author, Aug. 19, 2015.
170 PUB Singapore, “Simple Ways to Reduce Water Usage.”

http://www.pub.gov.sg/conserve/WaterReductionMeasures/Documents/dr
yWeatherFlyer.pdf
171 Khew, Carolyn. “Water levels in Linggiu Reservoir hit new low.” The

Straits Times, Apr. 13, 2016.

172 Dr. Jeffrey Yee, interview by author, Aug. 13, 2015.
173 Nelson Benjamin, “Proposed Johor multi-billion-ringgit Forest City

Project scaled down,” The Star, Jan. 15, 2015.

174 Jassmine Shadiqe, “Forest City to create 250000 jobs,” The New

Straits Times, Mar. 24, 2015.

175 Forest City DEIA Vol. 4 Sec. Ac, 3-4
176 Hana Badriah, interview by author, Aug. 19. 2015.
177 Forest City DEIA Vol. 5 Sec. B6, 24.
178 Dr. Serina Rahman, interview by author, Jul. 17, 2015; Bakhtiar Jaffar,

interview by author, Aug. 1, 2015; Abu Talib bin Khamis, interview by

author, Aug. 17, 2015.
179 Forest City DEIA Vol. 5 Sec. B6 (300000); Dr. Runze Yu, interview by

author, Jan 16, 2016. (700000)

180 Kobie, “Malaysia’s city of the future is an uncanny valley.”
181 Forest City DEIA Vol. 4 Sec. Ac, 3-4
182 “Country Garden’s sukuk a ‘tough sell,’” The Straits Times, Sep. 11,

2015.
183 Dr. Jeffrey Yee, interview by author, Aug. 13, 2015.
184 Forest City DEIA Vol. 5 Sec. C, 3.
185 See, for example, “Somerset Puteri Harbour Nusajaya: Overview,”

Somerset Serviced Residence, May 13 2016.

http://www2.somerset.com/en/malaysia/nusajaya/somerset_puteri_harbou
r_nusajaya.html
186 Forest City DEIA Vol. 5 Sec. C, 9.

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187 Principally, Altschuler and Luberoff, Mega-projects, 228

188 Forest City DEIA Vol. 5 Sec. B6, 25.
189 Shadiqe, “Forest City to create 250000 jobs.”
190 “Forest City Project FAQ,” Country Garden Pacificview

https://cgpvforestcity.wordpress.com/category/forest-city-project-faq/
191 Kennedy, Loraine. "The politics and changing paradigm of megaproject

development in metropolitan cities." Habitat International 45 (2015), 164.

192 Forest City DEIA Vol. 3, 1.
193 Bakhtiar Jaffar, interview by author, Aug. 1, 2015.
194 Forest City DEIA Vol. 3, 31.
195 Personal visit to Forest City reclamation site
196 Dr. Daniel Freiss, interview by author, Jul. 19, 2015.
197 Ibid.
198 Dr. Lena Wong, interview by author, Aug. 1, 2015.
199 Forest City DEIA Vol. 2 Sec. 8, 5.
200 Dr. Daniel Freiss, interview by author, Jul. 19, 2015.
201 UKM Pakarunding Sdn. Bhd. “Shoreline Management Plan for Iskandar

Malaysia Volume 1: Main Report” Nov 3 2010., i

202 Sock Ken, Low. “DEIA report lacks scientific data, says environmental

activist.” The Sun Daily. Jan 7 2015.

203 Dr. Lena Wong, interview by author, Aug. 1, 2015; Bakhtiar Jaffar,

interview by author, Aug. 1, 2015.

204 Ooi Boon Leong, email correspondence, Aug. 19, 2015.
205 Dr. Lena Wong, interview by author, Aug. 1, 2015; Bakhtiar Jaffar,

interview by author, Aug. 1, 2015.

206 Ibid.
207 Ibid.
208 Bakhtiar Jaffar, interview by author, Aug. 1, 2015.
209 Global Press Conference Forest City brochure
210 Personal recordings made near Kampong Pendas
211 “Green Capital” brochure
212 Dr. Lena Wong, interview by author, Aug. 1, 2015; Bakhtiar Jaffar,

interview by author, Aug. 1, 2015.

213 Forest City DEIA Executive Summary, 2.
214 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015
215 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015
216 See Ahankoob, A., S. R. E. Morshedi, and K. G. Rad. "A

Comprehensive Comparison between LEED and BCA GreenMark as

Green Building Assessment Tools." The International Journal Of
Engineering And Science (IJES) 2.7 (2013): 31-38. For a comprehensive
comparison between LEED and BCA Green Mark assessment
217 Veron Ng, interview by author, Jan. 28, 2016.
218 Ibid.

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219 Veron Ng, interview by author, Jan. 28 2016.

220 Comprehensive Development Plan for SJER (2006) 1-1
221 Rizzo and Khan “Johor Bahru's response,” 158.
222 Personal visits by author to University Technology Malaysia.
223 Rizzo and Khan, “Johor Bahru's response,” 158.
224 Dr. Runze Yu, interview by author, Jan. 16, 2016.
225 e.g. Elsidafy, Mohammed. “Nakheel a PJSC, appeal court told.”

Emirates 24/7 News. Aug 17 2009

226 Dr. Runze Yu, interview by author, Jan. 16, 2016.
227 Ibid.
228 Ibid.
229 Ibid.
230 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015.
231 Veron Ng, interview by author, Jan. 28, 2016.

232 Kennedy, "The politics and changing paradigm,” 167.

233 Swyngedouw et al., "Neoliberal urbanization in Europe,” 546-548.
234 Comprehensive Development Plan for SJER (2006), 1
235 Ibid.
236 “About IRDA,” Iskandar Regional Development Authority.
http://www.irda.com.my/about-irda.htm
237 For example, Forest City DEIA Vol. 5 Sec. B6, 25.
238 Forest City promotional video
239 Ibid.
240 “Green Capital” Brochure
241 Ibid.
242 Special Issue for Forest City’s Global Release
243 Forest City promotional video
244 “Green Capital” Brochure
245 Forest City promotional video
246 “Green Capital” Brochure
247 Forest City promotional video
248 “Green Capital” Brochure
249 Forest City promotional video
250 Forest City promotional video
251 Global Press Conference brochure

252 Global Press Conference brochure

253 “Green Capital” Brochure
254 Pauline Ng, “Forest City’s slew of incentives seen as a big plus,” The
Business Times, Mar. 9, 2016.
255 Michael Lim, “Country Garden’s big sell,” The Edge Property, Feb. 16,
2016.
256 From the Forest City "Green Capital" brochure distributed at the global

press conference in January 2016

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257 Swyngedouw et al., "Neoliberal urbanization in Europe,” 547

258 Nicole Kobie, “Malaysia’s city of the future is an uncanny valley,”
Wired, Mar. 22, 2016.
259 Forest City DEIA Vol. 5 Sec. B6
260 Country Garden promotional video
261 See, for example, Diane Stone, "Transfer agents and global networks

in the ‘transnationalization’ of policy," Journal of European public policy

11, no. 3 (2004): 545-566.
262 Olds, "Globalization and the production of new urban spaces,” 1717.
263 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015.
264 Veron Ng. interview by author, Jan. 28, 2016.
265 See Chapter IV, Section “Outside Actors”
266 See Chapter IV, Section “Lack of Compliance”
267 Lena Wong, interview by author, Aug. 1, 2015.
268 See http://www.mpjbt.gov.my/en/home for details on the council’s

operations
269 Hana Badriah, interview by author, Aug. 19, 2015.
270 Ibid.
271 Ibid.
272 National Land Code of Malaysia
273 Iskandar Regional Development Authority, “Shoreline Management

Plan Blueprint for Iskandar Malaysia,” 2011; Prof. Maketab Muhamad,

interview by author, Aug. 6, 2015.
274 Prof. Maketab Muhamad, interview by author, Aug. 6, 2015.
275 Hana Badriah, interview by author, Aug. 19, 2015.
276 Prof. Maketab Muhamad, interview by author, Aug. 6, 2015.
277 Ibid.
278 Lena Wong, interview by author,
279 Bakhtiar Jaffar, interview by author, Aug. 1, 2015.
280 Dr. Serina Rahman, interview by author, Jul. 17, 2015.
281 Dr. Serina Rahman, interview by author, Jul. 17, 2015.
282 Forest City DEIA Vol. 5 B6
283 Dr. Serina Rahman, interview by author, Jul. 17, 2015.
284 Prof. Maketab Muhamad, interview by author, Aug. 6, 2015.
285 Dr. Lena Wong, interview by author, Aug. 1, 2015.
286 Fong, Kathy and Tat, Ho Kay. “Cover Story: Forest City poses no

threat to anyone, says ED.” The Edge Weekly Oct 23, 2014.
287 Fong, Fernando. “DEIA study must engage locals, says

environmentalist.” The Rakyat Post. Sep 25 2014.

288 Chen Shaua Fui, “Forest City resumes but GDV shrinks 25% to

RM450b.” The Edge Markets. Mar 20 2015.

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289 Othman, Ahmad Fairuz. “Developers of coastal and riverine projects

must contribute to Johor Fishermen Development Fund.” The New Straits
Times. May 8 2015.
290 “Transcript of Senior Minister of State for Foreign Affairs Masagos

Zulkfli’s reply to Parliamentary Questions” MFA Press Release, Jul. 9,

2014.
291 Ibid.
292 Dr. Runze Yu, interview by author, Jan. 16, 2016.
293 Ibid.
294 Forest City Promotional Video
295 See e.g. Forest City DEIA Vol. 5 Sec. B6
296 “RM 290 billion profit over 30 years for controversial Johor project, says

report.” The Malaysian Insider, Sep. 15, 2014.

297 Forest City Promotional Video; “Green Capital” Brochure
298 Michael Grove, interview Libbie Cohn, Dec. 2, 2015. It was actually the

second, after Danga Bay.

299 Dr. Jeffrey Yee, interview by author, Aug. 13, 2015.
300 Dr. Runze Yu, interview by author, Jan 16, 2016.
301 Dr. Serina Rahman, interview by author, Jul. 17, 2015.
302 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015.
303 Kobie, Nicole. “Malaysia’s city of the future is an uncanny valley.”

Wired, Mar. 22, 2016.

304 Hana Badriah, interview by author, Aug 19, 2015.
305 Ibid.
306 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015.
307 Duke, Jennifer. “Ryde Garden stage two sells 55% at Saturday

launch.” Property Observer, Nov. 17, 2014.

308 Lawes, Anony. “Country Garden says Australia’s slow planning

process has forced it to delay projects.” Domain, Nov. 10 2015,

309 See Chapter III section on Baltic Pearl
310 See Chapter III section Greenland’s overseas projects
311 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015.
312 Jassmine Shadiqe, “Forest City to create 250000 jobs,” The New

Straits Times, Mar. 24, 2015.

313 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015.
314 Ibid.
315 Ibid.
316 “Green Capital” Brochure.
317 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015.
318 While mixed-use, it is primarily residential and strongly resembles other

Country Garden projects on mainland China. There is no pretense of

creating a new city or attracting industries to the site. Commercial tenants
would be primarily oriented towards retail.
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319 Michael Grove, interview by Libbie Cohn, Dec. 2, 2015.

320 Ibid.
321 Altschuler and Luberoff, Mega-projects, 4.
322 Swyngedouw et al., "Neoliberal urbanization in Europe.”
323 Forest City Promotional Video.

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