The third runway project is Hong Kong’s second largest reclamation project (the first largest being the already established Chek Lap Kok Airport). Over 650 hectares of important dolphin habitat will be lost.
The EIA report deliberately avoided the issue of permanent habitat loss during the construction phase under the impact assessment
- Effective construction phase compensation measures would be needed for such permanent loss of habitat starting in 2017, and can not be delayed until the construction is finished in 2023.
- However, such compensation measure (i.e., new marine park establishment) has only been proposed to be implemented during the operational phase, which is a clear violation of the EIA Technical Memorandum (TM).
The negative impacts of temporarily affected open waters of 981 hectares on dolphins during the construction phase were not properly assessed in the EIA report
- There will be a huge volume of moving and stationary vessels in this area that would displace dolphins from the area, and the silt curtain with floating booms may also affect dolphins in gaining access to this habitat during the construction phase.
- Along with the 650 hectares of reclamation, the total area of 1,631 hectares will not be available to dolphins during the projected seven-year construction phase in the worst-case scenario, and such significant impact was not described and predicted as required by the TM.
The acoustic survey results from the EIA report revealed that the proposed footprint of 3RS can potentially be important dolphin habitat at night, with the conclusion that it may be used more often at night with potential greater importance
- The project proponent should conduct a more comprehensive study to understand the function of the 3RS footprint as night-time dolphin habitat in order to identify the significance of habitat loss as a result of the 650 hectares of reclamation and an overall 1,631 hectares of sea area that will be seriously disturbed during the construction phase.
- It should also be noted that massive reclamation should be avoided in an important and sensitive habitat for activities that serve important functions, either at night or during the day, to the dolphins.
The loss of important habitat at the 3RS footprint will be a serious threat to the survival of the northern social clusters of 65 individuals that inhabit North Lantau waters regularly in the past decade
- In the EIA report, the uniqueness of this habitat to these 65 individuals from the northern social cluster has not been addressed adequately, nor have the impacts by the reclamation on the survival of these individuals and thus also the impacts on another social cluster of dolphins in West Lantau been examined.
The massive habitat loss of 3RS will pose the biggest threat to the dolphins in North Lantau since the reclamation in the mid-1990s for the Chek Lap Kok Airport
- In light of the significant decline in abundance and cumulative impacts in North Lantau waters since the airport construction, the EIA report should model the trend in dolphin abundance and habitat use in North and West Lantau would be before, during and after construction works in the current impact assessment as required by the TM.
As dolphins will almost certainly be displaced from the works area as well as North Lantau waters during the construction phase, the project proponent should provide critical information or predictions on where the dolphins may vacate to during the seven-year construction works period according to the TM requirement
- The EIA report briefly mentioned that the dolphins may shift their range into Chinese waters, but this prediction was not supported and justified by any evidence for such cross-boundary movement, and whether the dolphins’ chance of survival would be seriously reduced when moving across the border.