D.2. states that "the environmental impacts of the project are not significant"  .
However D.1. states that the project is not required to prepare an EIA. it then goes onto list 5 environmental impacts, of which (b) is incorrect and (d) is not an environmental impact at all, but an economic one.  With regard to (b)" it reduces waste dumping at the mill", there is no waste dumping at the mill - all the EFBs come from 60 km around and will need a material amount of lorry journeys and road miles (see Section B of the PDD). The impact of all this extra transport is not mentioned at all, despite the unsuitability of many of the roads in the area for increased lorry traffic, and the increased road-kill that such journeys will necessarily have - never mind the danger to human health & safety from this increased traffic.
If there is no EIA, how can the PO and DOE state with confidence that (D.2.) " the environmental impacts are not significant"? There has been no analysis done of how long and how much fruit bunches will have to be piled up next to the power plant, and how the leachate from these piles will be prevented from entering the water system.


Para 37c of VVM puts a requirement on all PPs to analyze whether environmental impacts are likely to be significant, this applies whether or not the host country has a requirement to undertake an EIA.  This should be applied by the DOE to all projects, and in particular to projects undertaken in environmentally and socially sensitive areas such as Sabah.