Template for Feedback on Bukit Brown



The following is a template for making a representation  on Bukit Brown in the draft master plan 2013.  It outlines the applicable statues, presents  the case for preserving Bukit Brown and provides an option for you to pen in your own words, why Bukit Brown is important to you and Singapore.

The closing date is 19 December, 2013. Please do not delay and send it directly to the email of Benny Lim: MND_benny_lim@mnd.gov.sg.

Please bcc your submissions to a.t.bukitbrown@gmail.com  if you are agreeable to allow bukitbrown.com to extract personal anecdotes for a separate blog post

More on the master plan and feedback process here

The URA draft master plan website here


Mr. Benny Lim

Permanent Secretary

Ministry of National Development


Dear Mr. Lim,

I, the undersigned, am writing to make a submission about the recently released URA Draft Master Plan 2013 under rules 5 and 6, Part II of the Planning Act (Chapter 232, Section 10), “Planning (Master Plan) Rules”, “Objections and Representations” and “Approval of Proposal”, which state the following:

Objections and representations

5.  Any objection to or representation concerning a proposal for an amendment to the Master Plan shall be in writing and shall be —

(a) submitted to the Permanent Secretary, Ministry of National Development within the period specified under rule 4(a); and

(b) accompanied by a statement of the reasons or explanations therefor.

Approval of proposal


—(1)  Except where the Minister is of the opinion that an objection or representation is of a frivolous nature, the Minister shall afford to any person whose objection or representation was received by him within the period specified under rule 4(a) and has not been withdrawn, an opportunity of appearing before and being heard by a person or persons appointed by the Minister for the purpose, or cause a public inquiry to be held in accordance with Part III.

(2)  The Minister, after considering —

(a) the proposal for an amendment to the Master Plan;

(b) the Master Plan;

(c) any objection or representation which has been received by him within the period specified under rule 4(a) and which has not been withdrawn; and

(d) in a case where a hearing or public inquiry has been held in accordance with Part III, the findings and conclusions submitted to him in accordance with rule 14, may approve, with such modifications as he may consider necessary, or reject the proposal for the amendment to the Master Plan in whole or in part.

(3)  Notwithstanding rule 4, the Minister, if satisfied that a proposal for an amendment to the Master Plan is not material in nature, may approve the proposal without any notice of the proposal being published.

Specifically, I submit my representation concerning the preservation of the Bukit Brown area (which includes Bukit Brown Municipal Cemetery, Lao Sua, Kopi Sua, Seh Ong) for the conservation of Singapore heritage and nature. The Draft Master Plan 2013 indicates that much of Bukit Brown will become a built-up residential area with a dual four-lane carriageway (hereafter, “highway”) passing through. The area marked for residential use in the Draft Master Plan 2013 is different from the previous 2008 Master Plan, and significantly reduces the size of Bukit Brown Cemetery. The highway cutting across Bukit Brown was not in the 2008 Master Plan. The Environmental Impact Assessment for the bridge component of the highway has not been made public for the public to understand the situation and if applicable, take any necessary mitigating actions to their own properties on lower ground than Bukit Brown.

I would like the Ministry of National Development and relevant state agencies to conserve Bukit Brown, given its multi-layered historical significance for our young city-state.

First, it is the final resting place for many of Singapore’s pioneers going back to the nineteenth century. While the cemetery was in operation between 1922 and 1973, the period it covers extends beyond that, as tombs as early as the 1830s have been found there, indicating the earliest pioneers from the time of Sir Stamford Raffles. Therefore, Bukit Brown is an important time capsule of the historical story arc of Singapore as an important maritime node of Southeast Asia to its present day incarnation. The links to other Straits Settlements sites and thriving regional towns make Bukit Brown important not just for Singapore history but underscores the links to our neighbours, all the more important in today’s globalized economic system. It is a story arc that covers practices under imperial China and colonial Southeast Asia right up to independence and recent history. There are tombs with Chinese imperial, Chinese agrarian, Japanese imperial,  Roman, Confucian and inventive calendars, and inscriptions in Dutch, Thai, English, Hokkien, Mandarin and Japanese.

A battle was fought there in World War II and according to the second generation tomb keepers, their parents spoke of mass civilian graves.   The battle felled English, Australian, Indian and Japanese soldiers as well as local civilians.  There are still soldiers missing in  action in this battle.  Battlefield archaeologist Jon Copper has described Bukit Brown as one of the rare battlefields that remain intact from World War II, as demonstrated by the British and Japanese wartime maps, during the Battle of Adam Park. This is all the more poignant as we soon approach the 70th anniversary of the Liberation of Singapore in 2015.

Malays used to live in the kampungs along Kheam Hock Road and the greater Bukit Brown area on the Police Academy side near Lao Sua. Jon Cooper has uncovered evidence Indian soldiers were massacred along Kheam Hock Road, abutting Bukit Brown and Lao Sua.

Bukit Brown therefore presents itself as a destination for education for  local schools and great potential for education tourism for schools overseas keen to study history, society and culture, as well as war histories. (This is already happening.) The artifacts there are unique and not found anywhere else in the world. The potential for tourism is great, including war site tourism, making Bukit Brown unique.

In essence, Bukit Brown has clearly demonstrated multi-cultural, multi-ethnic histories and wartime history intertwined into its seemingly mundane role as a mere cemetery. This gives it unique value that deserves re-consideration under the Masterplan.

Beyond its historical significance, the Bukit Brown area serves as an urban heat sink and refuge for endangered bird species. As a heavily vegetated area, Bukit Brown also mitigates against surface run-off and consequent flooding. Bukit Brown’s flood mitigation function may be especially important given that the 2013 Commission on Drainage Design and Flood Prevention Measures Final Report states that Singapore may be facing increasingly heavy rainfall. I also note that the recently concluded Our Singapore Conversation notes that 62% and 53% of Singaporeans respectively support the protection of green spaces and heritage sites over infrastructure construction. This is a majority of Singaporeans.

Conserving Bukit Brown is also consistent with the current effort to inscribe the Singapore Botanic Garden as a UNESCO World Heritage Site, since the former is listed on the 2014 World Monument Fund Watch List for endangered heritage sites. Many World Monument Fund Watch List sites like Georgetown in Malaysia later became inscribed as UNESCO World Heritage Sites. Protecting Bukit Brown in our Nation’s development plans demonstrates Singapore’s consistency on heritage protection and commitment to the UNESCO Convention, to which Singapore is a signatory. Obvious damage to and destruction of Bukit Brown may stand at odds with efforts to inscribe the Singapore Botanic Gardens as a UNESCO World Heritage Site. Bukit Brown’s proximity to the Singapore Botanic Gardens allows visitors to easily combine their experience of Singapore’s colonial history with a rich understanding of Singapore’s immigrant history.

Notably, Bukit Brown is one of Singapore’s top visitor sites and a Traveler’s Choice Award Winner for 2013 according to TripAdvisor, a respected online tourism portal, despite limited public transportation access and amenities. This is potential that should be looked into seriously.

<Insert any personal anecdotes here on why Bukit Brown should be conserved, or how it has moved you to a deeper understanding of Singapore and your own identity>

I hope you will protect Bukit Brown and Singapore’s historical, cultural, wartime and natural heritage for future generations, and will have an open discussion on how best to protect Bukit Brown and other heritage and nature sites affected by the proposals in the URA Draft Master Plan 2013. National development includes supporting our Nation’s sense of identity and belonging across generations in addition to infrastructure. I look forward to hearing from you. Please feel free to contact me at:

<email; contact number>




 Bukit Brown gates _ public domain