Proposed Retained Area (PRA) should retain as many Areas of High Ecological Value (AHEV) as possible, with accountability for chosen areas and monitoring of ecosystem functions. The AHEVs make up the site’s ecological backbone, bringing together native-dominated secondary forest, abandoned-land forest, and the freshwater stream that support habitat continuity toward Clementi Forest. Separately, about 8 ha of the roughly 23 ha site will be retained as part of the PRA, while about 15 ha will be cleared for housing. However, much of the AHEVs are not clearly designated as part of the PRA. Disruption in the surrounding area will cause edge effects if only some portions of the AHEV are kept, making it difficult to retain ecological function. Hence, while the quantitative scoring system for AHEVs could help identify priority areas, we should aim for maximal contiguous retention of high-scoring patches to minimize the fragmentation of the site’s ecological backbone. Furthermore, to ensure accountability, the patch-level scoring data used to determine retention priority should be made available in the Environmental Monitoring and Management Plan (EMMP), and assess of how much of the ecosystem functions are being preserved.

Connectivity to Clementi Forest is referenced clearly, but not yet detailed in implementation. NParks' Ecological Profiling Exercise (EPE) has mapped core habitats and corridors across Singapore. It is good that the EPE is referenced directly in the final decision so this site is assessed against wider landscape-scale priorities rather than treated as an isolated parcel. However, the current recommendation to merely study the restoration of the Old Jurong Line (OJL) bridge across Sunset Way should be converted into a firm implementation commitment with a defined timeline. Other design specifications should be refined to include taxon-specific features, such as rope bridges for arboreal fauna or specific underpass dimensions for ground-dwelling species identified in the surveys.

Baseline survey effort was useful but still limited: While the survey captured a significant baseline, the report acknowledges its "rapid nature" and that data collection provides only a "snapshot" of ecological communities. Camera traps ran for an average of 69 trapping nights, bat bioacoustics for only eight detection nights, and roadkill checks yielded no findings. These windows fall short of a full range of seasonal cycles and miss migratory bird months. Because six conservation-significant species were already found in this limited survey period, it is reasonable to argue that longer or seasonally extended surveys could identify additional species or more complete habitat use patterns. Hence, it is recommended that the EMMP includes a requirement for supplementary pre-construction baseline monitoring. This would extend data collection beyond a mere snapshot, to ensure that the finalised Wildlife Shepherding and Response Plans are informed by a more complete understanding of migratory and resident species movement.

Residual biodiversity impact remains material. It is a significant point of concern that even after all proposed mitigation measures, the residual impact on biodiversity remains rated as "Major Negative" (with a post-mitigation Environmental Score reaching as low as -135). The EIA is transparent that this rating stems from the loss of over 50% of high-value habitats like the Abandoned Land Forest and the reduction of habitat for the globally Critically Endangered Straw-headed Bulbul. Given this "Major Negative" classification, the final development decision should include an explicit justification for accepting this level of residual loss and investigate whether the residential building footprints can be further adjusted to increase contiguous habitat retention beyond the current 20m internal corridor.

Strengthen accountability for mitigation effectiveness. The EIA relies on an adaptive management framework where measures are reassessed if, for example, roadkill is encountered during daily checks. However, the effectiveness of these claims depends entirely on the accuracy and oversight of the Monthly Environmental Performance Reports (EPR). To ensure these measures materially reduce harm in practice, it is recommended that the EPR logs be subject to independent stakeholder review or public disclosure. This transparency would ensure that the "adaptive" nature of the EMMP leads to genuine site-level corrections rather than simply documenting the ongoing degradation of the site’s ecological function.

Mitigation claims would benefit from more evidence: Measures such as phased clearance, wildlife checks, salvaging, and retained green corridors help. There should also be evidence from Singapore or comparable local projects showing that each measure materially reduced harm in practice. The effectiveness of the measures should be measured against a fixed baseline to study survival, regeneration, and fauna movement and inform future regeneration efforts after the construction, and for future projects as well.

MOST IMPORTANTLY: Brownfield development should come before new clearance; protecting old-growth takes precedence over reforestation. The clearest public-interest argument is not that all development should stop, but that HDB and relevant agencies should explain why this greenfield site is needed before more intensive use of ageing or underused land elsewhere is ruled out. The One Million Trees movement is a valuable program, but new planting cannot replace the structure and species already established in existing forest. Hence, the EIA should publish the housing yield the forest parcel is expected to deliver, and compare it against what existing sites could absorb, e.g. by redeveloping ageing HDB precincts/ GCB plots nearby, before any clearance proceeds.