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

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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

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Figure 2 WWF’s Map of Threats to the Chinese White Dolphin