To Secretary for the Environment, Director of Environmental Protection,
The Environmental Life Science Society, SS, HKUSU (the Society) is deeply disappointed about the endorsement of the ‘Expansion of Hong Kong International Airport into a Three-Runway System’ environmental impact assessment (EIA) with conditions on 15 September. The Society requests the Environmental Protection Department to reconsider the negative impacts of the project to the marine ecology and the efficiency of the mentioned mitigation measures before issuing the environmental permit, in order to prevent irretrievable impairment to the natural environment.
1. Effectiveness of the marine park is questionable.
The Advisory Council on the Environment (ACE) suggests 20 conditions with which the EIA is passed. The conditions include advancing the preparatory work for the designation of the marine park (i.e. study on the details of the designation, consultation with stakeholders and incorporation of enhancement measures) and a marine park proposal after consulting the Agriculture, Fisheries and Conservation Department (AFCD). Independent funds, including the Marine Ecology Enhancement Fund and Fisheries Enhancement Fund, should be set up as well. Plans of the measures should be submitted to ACE for comment prior to submitting to DEP. DEP is responsible for approving before commencement of the construction works. However, the ACE only requires the designation of the marine park to be completed before operation of the project. That is, the problem of “Develop first, Conserve later” is not solved. Reclamation seriously damages the marine habitat and no one can ensure the return of Chinese White Dolphins and other marine fauna.
2. Designation of the marine park is insecure.
The designation of marine park has to go through a series of complex process and public consultation is included. Airport Authority Hong Kong, ACE and even AFCD are not able to guarantee the marine park can be brought about. According to the Marine Parks Ordinance, the draft map of the proposed marine park should be make available for public inspection and the public can send written statement of their opinion to AFCD, which has the right to amend the draft map after considering the public’s objection. The draft map is then submitted to Chief Executive in Council for approval. The proposed Southwest and Soko Islands Marine Parks were shelved due to fishermen’s objection in 2002. Moreover, it is important to note that apart from the 2,400 hectare marine park proposed in the Third Runway EIA, the proposed mitigation measure for the construction of Hong Kong-Zhuhai-Macau bridge is also a marine park which covers 700-800 hectares of the sea near the Brothers Islands. In addition to the above proposed marine parks for mitigation purpose, AFCD recently re-affirmed its commitment to the designation of the 660 hectare Southwest Lantau Marine Park and 1270 hectare Soko Islands Marine Park and hoped to complete the statutory procedure by early 2017. That is, there are 4 marine parks covering over 5000 hectares of the Lantau waters planned to be designated by 2023. As fishing and other fisheries activities are restricted in marine parks, the prompt designations of the marine parks may cause negative impacts on fishermen’s livelihood. Their objection may affect the designation of the marine parks. In short, there are unpredictable obstacles in setting up the marine park and no one can guarantee the designation of it. Yet, there is no doubt that reclamation will damage the marine environment. The proposal of the marine park is therefore an insecure mitigation measure.
3. The loss of habitat during construction is not fully compensated.
There will be a temporary works area of 981 hectares with construction vessel traffic and working barges operating during the construction period. As the construction is mainly carried out in the 650 hectare reclamation area, the EIA suggests that marine waters within the temporary works area will remain available for use by marine fauna and is not considered as habitat loss. Yet, although there is no physical barrier blocking the entry of marine fauna into the temporary works area, the frequent sea traffic and pollution will also hamper the utilization of the area, not to mention the construction will last for 7 years. The Society does not agree with the EIA that the temporary works area is not considered as habitat loss. The proposed designation of the marine park in 2023 cannot compensate for the immediate loss during construction period. In fact, the construction of Hong Kong-Zhuhai-Macau Bridge serves as a precedent. Since the start of the construction work in 2011, the number of Chinese White Dolphins near the constrcution area has been decreasing. Very few Chinese White Dolphins were sighted during surveys (even below 3). Whether the Chinese White Dolphins will return to the Brothers Islands marine park in 2016 is still questionable. The Society hopes that the Third Runway will not repeat the mistake.