Doubts about Mitigation Measures Prompt Green Groups to Recommend that ACE Members Reject the Third Runway EIA
The ACE will meet next Monday, 15 September, to discuss whether they will advise the Environmental Protection Department to give a green light to the EIA. There are still numerous outstanding questions regarding air quality and noise pollution that were not addressed in previous meetings, while AAHK’s new proposed “Marine Ecology and Fishery Enhancement Plan” is not an effective mitigation measure to alleviate impacts on the CWD.
The Marine Ecology and Fishery Enhancement Plan does not go far enough
Up until the end of August, AAHK had failed to address the ACE members’ concerns regarding the EIA, with the result that ACE members repeatedly and publicly expressed their disappointment with the document. However, it appears that after AAHK released a new 40-page plan to protect marine ecology on 2 September, its “Marine Ecology and Fisheries Enhancement Plan”, some ACE members changed their minds and began to show positive support for the EIA.
The problem is that this document lacks any effective measures to mitigate or compensate for the loss of marine habitats caused by reclamation work during the building stage of the third runway. As such, the green groups find it difficult to understand how ACE members can be inclined to endorse the EIA as a result
of this plan.
1. According to the EIA report, the waters to the west of HKIA (i.e. the plan’s “enhancement area”) have low marine traffic to begin with, so no real “enhancement” of the marine habitat would occur when high speed ferries to and from the Sky Pier are restricted, since these ferries do not pass through this area in the first place. The EIA report also indicates that the routes taken by construction vessels will not overlap with this enhancement area, as these vessels have other route options.
2. Some measures which AAHK claims will help improve the marine ecology, such as the deployment of artificial reefs and the release of fish fry, have not yet been scientifically proven to be applicable in the Hong Kong context and experts are doubtful that they will be effective. Research in other countries has found that such measures may lead to other problems.
This flawed and misleading enhancement plan should not be enough to satisfy ACE members’ concerns to the extent that they give a green light to the Third Runway EIA. We insist that conservation should be given a higher priority over development. We also insist that the marine parks recently announced by the government should be expanded to cover the entire core habitat of CWDs in west Lantau and linked with the existing Sha Chau and Lung Kwu Chau Marine Parks in order to optimize the conservation of Chinese white dolphins.
Air Quality Assessment
According to the EIA Study Brief, the operational air quality impacts (in the year 2031) within five km of the project boundary shall be quantified to determine whether the estimated pollutant levels comply with the relevant Air Quality Objectives (AQOs) at all Air Sensitive Receivers (ASRs).
A report made by AAHK in 2010 revealed that there would be non-compliance with the AQO for daily NO2 (i.e., 40μg/m3) at the ASRs in Tung Chung and Sha Lo Wan. Also, before the EIA’s public inspection period, AAHK held several briefing sessions regarding the preliminary assessment findings. At a briefing session in June, 2013, the NO2 level recorded at Tuen Mun’s ASR was indicated as “marginal”. However, six month later, AAHK stated that no non-compliance of AQO was predicted for identified ASRs at Tuen Mun. In the EIA report, the assessment findings for Year 2031 3RS scenario indicate NO2 levels will comply with the AQOs at all ASRs.
During the meeting with the ACE EIA sub-committee, AAHK did not clearly explain why how the NO2 levels would change from “non-compliance”/ “marginal” to “compliance”. Unfortunately, the ACE members did not request that the input parameters be disclosed, leaving this question unanswered.
Given the facts that the mitigation measures for Chinese white dolphins are still insufficient, and that there are still outstanding questions regarding to air quality and noise pollution that have not yet been addressed; we do not accept this EIA report, and we strongly urge the ACE to reject this flawed EIA.