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WWF-Hong Kong
香港中環纜車徑一號
No.1 Tramway Path, Central, Hong Kong
電話 Tel: +852 2526 1011 傳真 Fax:+852 2845 2764
wwf@wwf.org.hk wwf.org.hk
主 席: 楊子信先生 義務核數師:香港立信德豪會計師事務所有限公司 Chairman: Mr. Trevor Yang Honorary Auditors: BDO Limited 行政總裁: 顧志翔先生 義務公司秘書:嘉信秘書服務有限公司 CEO: Mr. Adam Koo Honorary Company Secretary:
義務律師:孖士打律師行 McCabe Secretarial Services Limited
義務司庫:匯豐銀行 Honorary Solicitors: Mayer Brown JSM
註冊慈善機構 Honorary Treasurer: HSBC
Registered Charity (Incorporated With Limited Liability) Registered Name: 世界自然(香港)基金會 World Wide Fund For Nature Hong Kong
Our Ref.: SHK/LDD 5/12
13 July 2012
Ms. Wong Sean Yee, Anissa, JP Director of Environment Protection Environmental Protection Department
46/F, Revenue Tower, 5 Gloucester Road, Wan Chai, Hong Kong (email: eiaocomment@epd.gov.hk)
By Email ONLY Dear Ms Wong,
Re: Expansion of Hong Kong International Airport into a Three-Runway System (ESB-250/2012) - Further information from the Applicant
WWF refers to the Project Proponent’s letter on the provision of supplementary information for the
captioned project. After studying the additional information, we still have serious concerns on the
captioned, and reiterate that the proposed project will incur various adverse impacts to the marine
habitats in the western waters of Hong Kong, as well as the species of conservation inhabiting in
the Project Site and its surrounding areas. In additional to our concerns submitted for the Project
Profile of the captioned project on 11 June 2012 (Appendix A), our further comments are as follows:
1. On-site Fisheries Survey
WWF strongly urges EPD to require the Project Proponent to conduct comprehensive on-
site fishery surveys at the Project Site and its surrounding area to provide detailed
fisheries resource information that can be used to assess the severity of the impacts.
To ensure that appropriate sampling technique with adequate information being collected, the
following should be taken into consideration:
i. Appropriate sampling gear should be selected depending on the type of fishery
resources affected; trawl gear may be used to sample demersal resources, while purse-
seine nets can be used for pelagic resources. Reef and coral communities may require
hook and line, traps, trammel nets, and/or underwater visual census techniques. Full
gear specifications must be given in the EIA report. The trawl survey shall be well-
designed (e.g. scale, course, frequency, duration) so as to avoid causing unnecessary
damage to the seabed;
ii. Survey design should include sufficient stations or replicates to enable statistical
analyses to be performed. Stations adjacent to and within the Project Site should be
compared;
iii. Information collected should include: species composition, abundance, size and/or
biomass, and value (commercially important or non-commercial). Identification to the
lowest possible taxon should be made to gain insight into the marine community of
concern and thus enable detection of changes; and,
iv. The survey should include at least one summer and one winter season’s sampling in
order to obtain clear patterns of species composition and abundance. Surveys should
not be conducted in the middle of a season to avoid effects from inter-annual variations
in the weather.
2. Hydrodynamics and Water Quality
WWF has serious concerns that the proposed third runway would affect the hydrodynamics of
the waters south and west to the Chek Lap Kok Island as well as the Tung Chung Channel,
and the natural coast of Lantau Island along San Shek Wan, Sham Wat and Tai O. The EIA
should fully address the potential impacts to the hydraulics of these areas where a number of
ecologically sensitive habitats, such as mangroves, seagrass bed and horseshoe crab nesting
sites, exist.
In addition, the proposed third runway would reduce the width of the waterway between Tuen
Mun and the airport island (Urmston Road and the waters to the south) from 4 km to about 3.3
km, or around an 18% reduction. It is important to note that the outfall from the Stonecutters
Island Sewage Treatment Works of the Harbour Area Treatment Scheme discharges the
treated effluent into the Ma Wan Channel. WWF has serious concerns on the potential water
quality impacts to at least four Water Control Zones (WCZs), including the North Western WCZ,
Western Buffer WCZ, Victoria Harbour WCZ and Southern WCZ, due to the anticipated
reduction in natural flushing effect from the Pearl River system and the effect on tidal flow
associated with narrower width of the waterway and change in hydrology.
3. Hong Kong International Airport Approach Area (previously called as Marine Exclusion
Zone)
In WWF’s opinion, the HKIAAA is likely to be of high ecological value, as the majority of the
area has remained undisturbed (i.e. no fishing activity is allowed) for almost 15 years. In the
letter, the Project Proponent also considered that it is an area of potential ecological concern,
and stated that this area will be covered by EIA. WWF reiterates that the HKIAAA should be
listed as one of the ecological sensitive receivers in the Study Brief for which a
comprehensive baseline survey and subsequent marine ecology impact assessment
should be conducted.
We trust you will give our comments due consideration.
Yours sincerely,
Dr. Andy Cornish
Director, Conservation
WWF – Hong Kong
WWF-Hong Kong
香港中環纜車徑一號
No.1 Tramway Path, Central, Hong Kong
電話 Tel: +852 2526 1011 傳真 Fax:+852 2845 2764
wwf@wwf.org.hk wwf.org.hk
贊助人: 香港特區行政長官 義務核數師:香港立信德豪會計師事務所有限公司 Patron: The Honourable Sir Donald Tsang, GBM, KBE Honorary Auditors: BDO Limited
曾蔭權先生, GBM, KBE 義務公司秘書:嘉信秘書服務有限公司 Chief Executive of the HKSAR Honorary Company Secretary: 主 席: 楊子信先生 義務律師:孖士打律師行 Chairman: Mr. Trevor Yang McCabe Secretarial Services Limited 行政總裁: 顧志翔先生 義務司庫:匯豐銀行 CEO: Mr. Adam Koo Honorary Solicitors: Mayer Brown JSM
註冊慈善機構 Honorary Treasurer: HSBC
Registered Charity (Incorporated With Limited Liability) Registered Name: 世界自然(香港)基金會 World Wide Fund For Nature Hong Kong
Our Ref.: SHK/LDD 5/12
11 June 2012
Ms. Wong Sean Yee, Anissa, JP Director of Environment Protection Environmental Protection Department
46/F, Revenue Tower, 5 Gloucester Road, Wan Chai, Hong Kong (email: eiaocomment@epd.gov.hk)
By Hard Copy & Email Dear Ms Wong,
Re: Expansion of Hong Kong International Airport into a Three-Runway System (ESB-250/2012)
ADDITIONAL COMMENTS
Following on from our submission on the captioned dated 6th June 2012, we understand that you
have decided not to reject the captioned Project Profile but ask for supplementary information from
Airport Authority Hong Kong, hence WWF is writing to express our views on issues that need to be
addressed in the Environmental Impact Assessment (EIA) report. The proposed megaproject will
undoubtedly cause serious adverse impacts to the marine environment of western waters, affecting
species of conservation concern such as Chinese white dolphins. In the view of our experts, the
information as outlined in the Project Profile has failed to identify a number of significant potential
impacts resulting from this project. Given the massive scale of the proposed third runway at Hong
Kong International Airport, and of the high likelihood that it will incur significant, irreversible impacts
to the environment, it is critical that the EIA Study Brief be comprehensive in its requirements to fully
address all the possible impacts.
2
The issues that need to be addressed are as follows:
1. Marine Ecology
a. Marine Exclusion Zone
The Chek Lap Kok Marine Exclusion Zone with a total area of ~1980 ha has been
established in the northern extent of the airport since its establishment in 1998 (See
Figure 1). No vessel is permitted to enter Zone 1-4 for safety and security reasons, and
as such, its underwater ecological condition and value remain unknown.
According to the Project Profile, a total of 650 ha to the north of the existing airport will
be reclaimed for the construction of third runway, resulting in the complete and
irreversible loss of around 300 ha of Exclusion Zone 3.
In WWF’s opinion, the Marine Exclusion Zone should be considered as a “non-statutory”
no-take marine protected area as no fishing activity is allowed. In fact, it is by far the
largest effective no-take zone in Hong Kong waters (the Cape d’Aguilar Marine Reserve
is around 20 ha), and is even larger than the Hoi Ha Wan Marine Park (260 ha). Since
the majority of the area has remained undisturbed for almost 15 years, and in particular
as no trawling has occurred, a richer and higher abundance of sessile marine fauna
including corals, as well as mobile reef fishes and invertebrates are expected to be
found inside, compared to the surrounding unprotected areas1. Many studies from
around the world have found increased diversity, density, biomass, and size, for fishes
(and to a lesser extent invertebrates) in no-take marine protected areas vs. fished
areas2. Such benefits develop within two to five years of establishment and continue to
build for decades3.
As such, WWF anticipates that Zone 3, an area that would be heavily impacted by
the proposed reclamation, is likely to be of high ecological value and should be
listed as one of the ecological sensitive receivers for which a comprehensive
1 Meinhardt Infrastructure and Environmental Limited. 2007. Consultancy for Environmental Monitoring and Audit for
Contaminated Mud Pit IV at East of Sha Chau (2000-2005). Nineteenth Quarterly Report for November to December
2005. Submitted to CEDD. 2 Halpern BS. 2003. The impact of marine reserves: Do reserves work and does reserve size matter? Ecological
Applications 13(1) 117-137
3
baseline survey and subsequent marine ecology impact assessment should be
conducted.
According to Technical Memorandum Annex 16: Guidelines for Ecological Assessment,
under Section 4 The Scope and Content of Ecological Assessment, “An ecological
assessment shall consist of... provision of comprehensive and accurate information on
the ecological baseline”. It is our understanding that no ecological surveys have been
conducted in the entire exclusion zone including Zone 3 ,. For the reasons stated here, it
is crucial to fill in the data gaps and collect baseline information by conducting a
comprehensive on-site survey inside the area, including but not limited to:
• Intertidal fauna survey
• Subtidal fauna survey
• Benthic community survey (including hard-bottom and soft-bottom survey)
• Artificial seawall survey
• Marine mammal survey (to investigate dolphin usage via vessel survey or land
based survey)
• Artificial reef survey
Since the proposed third runway will involve permanent loss of seabed and marine
habitats in the Marine Exclusion Zone, survey designs, statistical analysis and evaluation
of the results should follow the approaches adopted in the approved EIA of Development
of a Bathing Beach at Lung Mei, Tai Po (AEIA-123/2008), in which the project proponent
had to evaluate the overall ecological value of the habitat of Lung Mei Beach in the
context of other similar habitats within Plover Cove and Tolo Harbour/Channel4. We
consider the project proponent of the captioned should select at least five representative
reference sites in the western Hong Kong waters so as to establish the ecological profile
and evaluate the ecological value of the site. The project proponent should address the
potential ecological impacts in compliance with Basic Principles of the Environmental
Impact Assessment Process (EIAO Guidance Note No. 1/2010). In case the Marine
3 Gell FR, Roberts CM. 2003. Benefits beyond boundaries: the fishery effects of marine reserves. Trends in Ecology &
Evolution. 18(9) 448-455. 4 Additional Information in response to EPD’s letter ref. (92) in EP2/N5/C/46 Pt. 4 dated 5 February 2008. Application for
Approval of Environmental Impact Assessment Report. Development of a Bathing Beach at Lung Mei, Tai Po.
4
Exclusion Zone is of moderate / high ecological value, the option of avoidance (i.e. no
development) should be considered in the EIA.
b. Chinese White Dolphins
i. Information outdated
The ecological baseline information provided in the Project Profile on the Chinese white
dolphins (CWD) is out-of-date. The project proponent refers to the results of the CWD
monitoring in Hong Kong waters by Agriculture, Fisheries and Conservation Department
(AFCD) during the study period from April 2007 to April 2008, notwithstanding that the
results from the April 2010 to March 2011 study were published by AFCD in mid-2011 i.e.
far earlier than the preparation of this Project Profile5. It is a serious omission and as
such the project proponent has failed to apply its “best knowledge” at the time of the
submission of the Project Profile. The use of outdated dolphin data for the Project Profile
of such a large-scale development project is unacceptable and misleading, as the
dolphin population is no longer considered stable, but has recently shown significant
declines.
According to the AFCD’s 2010 report6, “During 2002-09, annual dolphin encounter rates
were fairly stable in Northwest and West Lantau, but appeared to decline in Northeast
Lantau in recent years”. Furthermore, according to the AFCD’s 2011 report, “the
combined dolphin encounter rate around Lantau showed a downward trend in recent
years, and such decline was also evident in examination of annual dolphin encounter
rates across Northwest, Northeast and West Lantau survey areas. Using line-transect
analysis, annual dolphin abundance was also estimated for each of these three areas.
The combined estimates from the three areas ranged from 75-158 individuals annually
during 2002-2010, with the ones in 2003 and 2010 being the highest and the lowest
respectively. All three areas showed noticeable declining trends during the past decade,
and autocorrelation test found such trends to be significant”. As such, in order to allow
the Director of Environmental Protection to impose appropriate requirements in the
Study Brief to evaluate the potential impacts of the third runway on an already declining
dolphin population, it is critical for the project proponent to include the latest available
5 http://www.afcd.gov.hk/english/conservation/con_mar/con_mar_chi/con_mar_chi_chi/con_mar_chi_chi.html
6 Hung, S.K. 2011. Monitoring of marine mammals in Hong Kong waters – Data collection (2010-11): final report (1 April
2010 to 31 March 2011). A report submitted to the Agriculture, Fisheries and Conservation Department of the HKSAR.
5
information at the time of submission of the Project Profile as well as in the EIA
report.
In addition, the newly released 2012 Chinese white dolphin monitoring report7 reveals
that the decline has not reversed. Together with the current adverse impacts arising from
high levels of marine traffic, particularly in relation to the operation of the SkyPier of the
Airport Authority Hong Kong, and threats from the Hong Kong-Zhuhai-Macao Bridge
project, the Chinese white dolphin’s population in Hong Kong will be very vulnerable and
susceptible to the new threats posed by the captioned project, in particular a large part
of their habitats will be lost from reclamation. The project proponent should include
assessment of the cumulative impacts associated with the operation of the SkyPier.
The use of outdated dolphin data for the Project Profile of such large-scale development
project is unacceptable and misleading. To conduct the dolphin impact assessment
properly, the project proponent has to use the most up-to-date dolphin
information (i.e. 2011-2012 AFCD Chinese white dolphin monitoring report8). The
project proponent should also explain how the impacts from direct and indirect
habitat loss be addressed.
It is WWF’s opinion that reversing the population decline and ensuring the long-term
survival of the population will depend on the ability of authorities to manage the impacts
of a multitude of threats across two jurisdictions and is therefore beyond what is possible
within an EIA. Steps should be taken urgently by the authorities to start formulating a
cross-boundary Chinese white dolphin management plan, and to ensure that all EIAs
related to the dolphins are designed to inform and support such a management plan.
ii. Deep Cement Mixing Method
Deep Cement Mixing (DCM) method will be adopted for the land formation directly
above the existing contaminated mud pits (CMPs), and due to height restrictions near
the airport area, the work barge can only travel and work at the Project Site at night9.
The project proponent, without consulting the public under the Foreshore and Sea-bed
7 Hung, S.K. 2012. Monitoring of marine mammals in Hong Kong waters – Data collection (2011-12): final report (1 April
2011 to 31 March 2012). A report submitted to the Agriculture, Fisheries and Conservation Department of the HKSAR. 8 http://www.afcd.gov.hk/english/conservation/con_mar/con_mar_chi/con_mar_chi_chi/con_mar_chi_chi.html
6
(Reclamations) Ordinance, undertook a DCM trial study at the northern extent of the
existing airport in February 2012. During the trial study, the project proponent set up a
dolphin exclusion zone with marine mammal observers using visual technique to monitor
if there were any dolphins spotted inside the zone. According to the representative of
Airport Authority during a meeting with green groups on 25 May 2012, such DCM works
need to occur at night because the height of the construction vessels are higher than the
height restriction of the airport while planes are landing and taking off. WWF considers
the project proponent should clarify if the reclamation works of the third runway using the
DCM method would be required to conduct at night time. WWF is doubtful of the
effectiveness of a dolphin exclusion zone at night as the visibility may be low (< 100
metres), which will make spotting dolphins difficult. We contend that the mitigation
measures proposed by the project proponent should be practical and effective, so as to
address the potential impacts and disturbance to the Chinese with dolphins.
iii. Underwater noise pollution
Marine mammals rely on echolocation, which is similar to sonar, for hunting,
communication and navigation. The construction of third runway will bring in additional
work barges and vessels to the sea areas around northern Lantau. The underwater
noise pollution from the increased marine traffic will cause acoustic disturbance to the
dolphins, which may result in behavioural changes due to increased stress and
subsequent displacement from important habitats. The latest AFCD dolphin study
reveals that the underwater noise from marine vessel did pose additional stress to the
dolphins inhabiting affected areas.
In order to assess the extent of impacts on the dolphins from the elevated
underwater noise, WWF requests that a baseline underwater acoustic study
should be undertaken, and subsequent impact assessment conducted.
iv. Marine Traffic
The proposed third runway will be located less than one kilometre from the boundary of
Sha Chau and Lung Kwu Chau Marine Park. This Park is considered to be a prime
habitat and one of the most heavily-utilised areas for the Chinese white dolphins in Hong
9 Wen Wei Po. 26 May 2012. 新跑道「拌合法」填海貴 4倍 減噪音利中華白海豚海床污泥坑變水泥柱 (A20)
7
Kong for many years10. Together with the establishment of the new Marine Exclusion
Zone, the sea area available for the vessels to navigate between the Marine Park and
the expanded airport will be greatly reduced and some vessels may be inclined to pass
through the Marine Park instead. However, the potential impact from the increase in
marine traffic inside the Marine Park during the operation phase has not been
considered in the Project Profile.
In view of this, WWF urges that the marine traffic and its associated impacts to
Chinese white dolphins in particular those inhabit at Sha Chau and Lung Kwu
Chau Marine Park during the operation phase should be included as one of the
assessment criteria in the Study Brief. This marine traffic impact assessment should
include, but not limited to:
• Review on current marine traffic in the water areas between the northern extent of
the airport and southern part of Sha Chau and Lung Kwu Chau Marine Park
(baseline) – Based on Automatic Identification System (AIS) and Radar data with
Visual Survey.
• Estimation of future marine traffic activity and routes associated with the proposed
development during both construction and operation phase
• Risk assessment and mitigation measures proposed for the conservation of
Chinese white dolphin from marine traffic impact
The project proponent should quantify the habitat loss for the species and the risk
of vessel collisions at both the construction and operation phases, and
demonstrate the project will not cause degradation to the ecological connectivity
(i.e. travelling corridors) between known areas of higher dolphin abundance.
v. Cumulative Impacts and Disruption of Dolphin Habitats and their Movement
The project proponent should address the cumulative impacts from mulitple
development in the habitats to Chinese white dolphins (Figure 2). In addition to all the
works within Hong Kong waters, the potential impacts to the migration of dolphins due
to the newly formed artificial island of the Hong Kong-Zhuhai-Macao Bridge to the west
of Tai O should also be considered.
10
Hung, S.K. 2012. Monitoring of marine mammals in Hong Kong waters – Data collection (2011-12): final report (1 April
2011 to 31 March 2012). A report submitted to the Agriculture, Fisheries and Conservation Department of the HKSAR.
8
Moreover, since the distance of the proposed third runway is less than 1 km to the Sha
Chau and Lung Kwu Chau Marine Park and in proximity to the proposed Brothers
Island Marine Park which are or will be established for the Chinese white dolphins, the
project proponent should investigate the potential impacts to such conservation
measures and suggest mitigation measures to address such impacts.
In addition, the project proponent should explictly examine the potential impacts on the
disruption of travelling corridors of individual dolphins among the core habitats
identified by AFCD11.
vi. Feasibility of New Marine Parks & Rerouting of Marine Traffic
The project proponent suggests that “subject to investigation, establishment of new
marine parks in dolphin active areas or expansion of existing marine parks will be
explored. Rerouting of marine traffic will also be considered, if feasible, as
compensation measures” (Section 5.4.2 of the Project Profile). However, according to
Section 4.4.2(k) of the Technical Memorandum, the EIA should only be considered
adequate if “the report has assessed and determined the feasibility, practicability,
programming and effectiveness of the recommended mitigation measures”. With
reference to Principle Five in the Basic Principles of the Environmental Impact
Assessment Process (EIAO Guidance Note No. 1/2010), the EIA recommendations
“should be sensible, practical and effective, with information about the 5 Ws (i.e. what
mitigation measures would be implemented, by whom, when, where and to what
requirements) and with clear definition of the responsibility for implementing the
recommended mitigation measures. The recommended measures should be easy to
enforce and can prevent environmental problems from occurring, rather than relying on
remedial measures after problems occur”. As such, we consider the project proponent
MUST confirm their proposed mitigation or compensation measures are feasible.
Regarding to the designation of marine parks and rerouting of marine traffic, formal
endorsement from the marine park authority and Marine Department MUST be
acquired, so as to demonstrate the feasibility of such compensation measures. This is
of particular importance as the scale of the proposed reclamation is the largest since the
enactment of the EIA Ordinance.
11
Hung, S.K. 2012. Monitoring of marine mammals in Hong Kong waters – Data collection (2011-12): final report (1 April
2011 to 31 March 2012). A report submitted to the Agriculture, Fisheries and Conservation Department of the HKSAR.
9
c. Subtidal Coral Communities
The majority of octocorals (including soft corals and gorgonians) inhabit in the eastern
waters of Hong Kong. In the AFCD commissioned territory-wide octocoral study12, out of
67 octocorals recorded in Hong Kong waters, only one gorgonian species, Guaiagorgia,
could be found in the western water areas. Its local occurrence was very restricted and
was classified as 1 (i.e. could only be found in one out of 103 sites surveyed). Its
abundance status is currently classified as globally rare13.
In the past, individuals of this pale blue gorgonian species have only been recorded
mainly in the western extent of Lantau and its surrounding waters, such as at Tuen Mun,
Tsing Yi14, The Brothers and Sha Chau and Lung Kwu Chau Marine Park15. As the
reclamation for the third runway is 650 ha, which will occupy relatively high proportion of
the western waters, the direct loss of these gorgonians is deemed as highly likely. WWF
believes that the conservation importance of this gorgonian species should be
reconsidered and re-evaluated, and proper mitigation measures such as coral
translocation should be adopted.
In addition, the report of the abovementioned AFCD octocoral study states “It is strongly
recommended to carry out more detailed surveys in this area, i.e. the western waters of
Hong Kong, in order to look for octocoral species that live in brackish
environment….there are still many unexplored areas in other part of Hong Kong. More
studies should be carried out to examine additional sites”. The coral distribution and
abundance in the western part of Hong Kong is still largely unknown due to the high
turbidity of western waters and lack of sampling effort, as such, WWF considers that, in
order to identify all existing coral communities (both hard corals, octocorals and black
corals) which could be affected by the work, the project proponent should conduct an
12
CUHK. 2010. Provision of Services on Reference Collection and Study on Octocorals and Black Corals in Hong Kong
waters. A report submitted to the Agriculture, Fisheries and Conservation Department of the HKSAR. 13
Fabricius K, Alderslade P. 2001. Soft Corals and Sea Fans: A comprehensive guide to the tropical shallow-water
genera of the Central-West Pacific, the Indian Ocean and the Red Sea. Published by the Australian Institute of Marine
Science. pp. 264. 14
CEDD. 2008. Providing Sufficient Water Depth for Kwai Tsing Container Basin and its Approach Channel. EIA report. 15
Meinhardt Infrastructure and Environmental Limited. 2007. Consultancy for Environmental Monitoring and Audit for
Contaminated Mud Pit IV at East of Sha Chau (2000-2005). Nineteenth Quarterly Report for November to December
2005. Submitted to CEDD.
10
extensive SCUBA dive/ trawling survey in the entire Project Site and its
surrounding waters (i.e. Sha Chau and Lung Kwu Chau Marine Park, The Brothers,
northern Lantau and Marine Exclusion Zone). The resulting information will be important
for the latter thorough assessment of impacts caused by the proposed work of third
runway construction and is essential for determining the necessity of additional
mitigation measures, i.e. post-construction coral monitoring surveys.
d. Marine Benthic Habitats
According to Session 3.3.4.2., “The potential impact on temporary reduction of intertidal
and sub-tidal habitats on the existing Airport Island would unlikely be significant as these
habitats could be readily recreated by recolonisation around the new land mass.” WWF
believes that this statement may not be true.
During 1996-2008, a total of 280ha of Penny’s Bay in the western waters was reclaimed
for the construction of a Theme Park. Before reclamation, nine species of hard corals
were recorded inside the bay area. Nine years after reclamation, only three species of
hard corals were found recolonised back in the disturbed area. Unexpectedly, a total of
nine species of soft corals not found in the bay before were recorded on the artificial
seawall of the reclaimed land16. According to the report, “…the findings of the current
Programme, artificial sloping seawalls support such communities in lower percentage
cover and diversity when compared to the conditions before the Penny’s Bay
reclamation during which a total of nine hard coral species with a total estimated cover of
9% was recorded for the coral assemblages in the shallow subtidal zone”. WWF
anticipates that any new land mass in the sea will change the hydrological profile of the
area, which may affect the species diversity, composition and abundance of marine
species such as corals that recolonise on the artificial substrate.
WWF urges the project proponent to conduct a comprehensive benthic survey to
reveal all the marine benthic species currently inhabiting in the Project Site and its
surrounding areas. A detailed assessment should be conducted subsequently to
determine the effectiveness of the new land mass for the recolonization of the
16
ERM. 2011. Penny's Bay three-year monitoring programme of the effectiveness of the sloping seawall. Final Report
submitted to CEDD.
11
marine species assessed taking into account the permanent change in
hydrodynamics flow (also see Section 3).
2. Fisheries
a. On-site Survey
WWF has previously voiced serious concern on the over reliance on Port Survey data
and a 1998 consultancy reports 17
during fisheries impact assessments (See Appendix
I – Letter to EPD dated 26 April 2011). There are strong ecological reasons to suspect
that considerable shortcomings will result from relying on these two sources alone to
provide baseline information for impact assessments, as they are inadequate on their
own for use in predicting potential impacts on fisheries resources without additional on-
site field surveys.
Port Surveys are grossly inadequate for identifying and quantifying fisheries resources
and important fisheries areas in Hong Kong. The nature of the Surveys (through fishers’
interviews) and frequency of conducting (i.e. every few years) cast serious doubts on the
quality and accuracy of the fisheries information. Since the Surveys relied almost entirely
on reported catches from fishers, the high sampling errors and systematic bias may
largely affect the accuracy of the estimates. In addition, the interview data is not ground-
truthed by actual fishing surveys. As the size of fish stocks often show major variances
from year to year due to large natural variations in recruitment, the every-several-year
Port Surveys should not be expected to reflect the state of current fisheries resources
with any accuracy several years after completion, not withstanding the inherent
weaknesses of an interview based methodology. The accuracy of the fisheries
production estimates from the Port Surveys was tested by highly respected fisheries
scientists in a report conducted by The University of British Columbia (UBC) for WWF in
200718. They used a method similar to that used previously by UBC scientists to cast
doubt over China’s fisheries production figures in the journal Nature, by comparing Port
Survey data against plausible fisheries production figures from similar locations across
the world’s oceans. They found that the median catch figures varied largely between two
17
ERM. 1998. Fisheries Resources and Fishing Operations in Hong Kong Waters. Report submitted to AFCD. 18
Sumaila UR, Cheung WWL, The L. 2007. Rebuilding Hong Hong’s Marine Fishery: An Evaluation of Management
Options. 131pp.
12
sampling years and concluded that the likelihood the Port Survey figures were accurate
was “low”.
The ERM fisheries report was completed over 14 years ago and given the rapid rate of
changes in the environment and changes to the local fishing activity, the information it
contains cannot be considered as up-to-date. Moreover, although the fish spawning and
nursery grounds were suggested in the report, these areas were not identified based on
directed sampling for fish eggs and larvae, or for juveniles, and do not give any
indication of season occurrences of habitat use by different species.
Despite the two primary sources of information for fisheries assessments being out-of-
date,,only one EIA has conducted additional on-site fish sampling survey to date (i.e.
Ichthyoplankton and Fish Post-Larvae Survey19). The Technical Memorandum Annex 17:
Guidelines for Fisheries Impact Assessment, under Section 3.1, stipulates that “A
fisheries assessment study shall provide adequate and accurate baseline data of a
proposed development site and its adjacent area of probable impact for accurate
prediction and evaluation of fisheries impacts”, and “The accuracy and usefulness of the
fisheries information obtained must be carefully evaluated before adopting it in the EIA
report… It there are doubts, they shall be verified by on-site survey(s)”. Using data
from Port Surveys and the aforementioned 1998 consultancy report is likely to lead to
inaccurate-estimation of the potential impacts from the Project to the fisheries (both
biological resources and fishermen’s livelihoods). The impacts on current and future
fisheries from the proposed massive reclamation, including fish eggs and larvae, can
only be assessed with any confidence by conducting on-site survey(s).
WWF strongly urges EPD to require the project proponent to conduct
comprehensive fishery surveys (field surveys of adults, juveniles, eggs and larvae)
at the Project Site and the surrounding area (including the Marine Exclusion Zone)
to provide detailed fisheries resource information that can be used to assess the
severity of the impacts.
19
ERM 2006. Liquefied Natural Gas (LNG) Receiving Terminal and Associated Facilities – South Soko EIA. EIA report
submitted to EPD.
13
b. Fisheries Modeling
In late 2011, WWF commissioned The University of British Columbia (UBC) to examine
the ecological and socio-economic impacts of two large reclamations (i.e. the Border
Crossing Facility for the Hong Kong-Zhuhai-Macao Bridge (BCF) and the proposed third
runway) on the recovery of the marine ecosystem, and in turn the development of
sustainable fisheries resulting from the forthcoming ban on trawling in Hong Kong20 (See
Appendix II – UBC Fisheries Modelling Report).
With the implementation of the territorial-wide trawl ban and without the construction of
BCF and third runway, biomasses of most groups of benthic invertebrates and fishes are
expected to increase over the 5-, 10- and 20- year time frames. However, the model
predicted negative impacts on benthic crustaceans, reef fish and non-reef fish by the
proposed development scenarios and that the impacts from the BCF and third runway
scenario are generally more than double the impacts from the BCF only scenario.
The BCF project was approved, it is currently under construction and tentatively will be
completed in 2016, while the construction of a third runway would lead to further loss of
habitat and impacts to the fisheries resources in western waters. WWF believes that the
modelling tool provides valuable new insights on the future impacts of reclamation of
third-runway on a variety of time-scales, and as such has practical application in
providing additional insight to the EIA. WWF urges the project proponent to collect
up-to-date fisheries data from an on-site survey, and to incorporate these and data
from the latest AFCD fishery resource survey into the modelling tool, to
investigate with more accuracy the magnitude of impacts on the recovery of
fisheries resources after the implementation of trawl ban.
c. Artificial Reef
Artificial reefs can potentially enhance fishery resources through the provision of
additional food and shelter, and deployment of artificial reefs has been proposed as a
mitigation measures for a number of development projects. The artificial reef project in
Hong Kong has been conducted for more than 15 years, however, no publised findings
have ever been released to unveil its effect on the fisheries resources in the western
20
Sumaila R et al. 2012. Modeling the socio-economic impacts of two large reclamations on the recovery of the marine
ecosystem and fisheries in Hong Kong. Final report submitted to WWF-Hong Kong.
14
waters, thus their effectiveness as a mitigation measure for this Project remains
unknown.
The artificial reefs may influence the type of fish aggregated, as the hard substrate
nature are mostly likely to attract the marine fish which favour reefs. It is questionable
whether artificial reefs deployed in western waters will be beneficial to demersal fish
species which inhabit soft bottoms. In view of this, WWF doubts that artificial reefs alone
will “serve to compensate the habitat for fish and CWD utilizing the proposed Project
Area and minimize the potential direct and indirect impacts on them during construction
and operation”.
WWF questions the effectiveness of deploying additional artificial reefs as the mitigation
measures in the western waters of Hong Kong, and urges the project proponent to
conduct a series of survey and assessment to prove if existing artificial reefs are
proving effective in enhancing fisheries resources.
3. Hydrodynamics
With reference to the proposed layout plan of the third runway, WWF has serious
concerns that the western portion of the proposed third runway would affect the
hydrodynamics of the waters south and west to the Chek Lap Kok Island as well as the
Tung Chung Channel and the natural coast of Lantau Island along San Shek Wan,
Sham Wat and Tai O. The EIA should fully address the potential impacts to the
hydaulics of these areas where a number of ecologically sensitive habitats, such as
mangroves, seagrass bed and horseshoe crab nesting sites, exist.
4. Carbon dioxide
WWF also considers that carbon dioxide is an environmental pollutant, and that
increases in ground and aviation emissions should be calculated and evaluated by the
Airport Authority, but recognise that carbon dioxde is not currently categorized as an air
pollutant under the Air Pollution Control Ordinance.
15
We trust you will give our comments due consideration.
Yours sincerely,
Dr. Andy Cornish
Director, Conservation
WWF – Hong Kong
16
Figure 1 The restricted areas of Hong Kong International Airport
WWF-Hong Kong
香港中環纜車徑一號
No.1 Tramway Path, Central, Hong Kong
電話 Tel: +852 2526 1011 傳真 Fax:+852 2845 2764
wwf@wwf.org.hk wwf.org.hk
贊助人: 香港特區行政長官 義務核數師:香港立信德豪會計師事務所有限公司 Patron: The Honourable Sir Donald Tsang, GBM, KBE Honorary Auditors: BDO Limited
曾蔭權先生, GBM, KBE 義務公司秘書:嘉信秘書服務有限公司 Chief Executive of the HKSAR Honorary Company Secretary: 主 席: 楊子信先生 義務律師:孖士打律師行 Chairman: Mr. Trevor Yang McCabe Secretarial Services Limited 行政總裁: 顧志翔先生 義務司庫:匯豐銀行 CEO: Mr. Adam Koo Honorary Solicitors: Mayer Brown JSM
註冊慈善機構 Honorary Treasurer: HSBC
Registered Charity (Incorporated With Limited Liability) Registered Name: 世界自然(香港)基金會 World Wide Fund For Nature Hong Kong
Figure 2 WWF’s Map of Threats to the Chinese White Dolphin
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