March 2023

Ms. LINN Hon Ho, Bernadette, JP
Secretary for Development
18/F, West Wing, Central Government Offices,
2 Tim Mei Avenue, Tamar, Hong Kong

Mr. FONG Hok Shing, Michael, JP
Director of Civil Engineering and Development
15/F, Civil Engineering and Development Building,
101 Princess Margaret Rd, Homantin, Kowloon

Dear Sir and Madam,
Green Power’s Comments on the Kau Yi Chau Artificial Islands Project

Despite the intense controversy, the authority insisted to put forward the latest proposal of the Kau Yi Chau Artificial Islands (KYCAI) project, one of the most large-scale reclamation projects in Hong Kong for public engagement (PE) in late December 2022. Green Power opposes the project due to the following reasons:

<u>Unconvincing Protection of Ecology</u>

1. The creation of 1000ha of land through reclamation poses direct and indirect impacts on the fragile ecosystem in the area, both during the construction and operation phases of the KYCAI. These include direct loss of marine habitats, as well as indirect reduction of habitat quality through alteration of ocean currents, degradation in water quality, reduction in home ranges and increase in human disturbance.

2. Although the PE materials state that the project footprint has avoided the habitats of important species, such a large-scale reclamation project would indeed directly infringe on their habitats, including the entire home range they need for breeding and foraging. One example is the White-bellied Sea Eagle, a Class I State-protected species. Sunshine Island and Kau Yi Chau in the Central Waters have been found to be nesting sites for the species. Although the PE materials claim that the proposed footprint of reclamation has avoided infringing onto the natural islands and should sufficiently protect the species, we opine that threats to such a species that is sensitive to human disturbance and requires an extremely large home range (which could range between 34.2-237.6km2) (i)(ii) cannot be eliminated.

3. Given the large area of land mass to be created, the narrow Y-shaped channel with width of less than 400m reserved between the artificial islands and the surrounding natural islands under the proposal, and the lack of scientific support for the effectiveness of hydraulic impact mitigation available to the public at this stage, we are not convinced that such a large-scale reclamation project could avoid adverse environmental and ecological impacts on the surrounding coastal habitats, species and water quality. Alteration of current flow within and around the project area appears to be certain, and any such alteration, whether through reduction or increase in current flow, would reshape the nearby coastal area through erosion or sedimentation, and directly or indirectly impact the inhabitants (e.g. corals) in these habitats.

4. Other indirect impacts, including noise and light pollution, increase in marine traffic and human disturbance would also be imposed on the wildlife communities in the nearby natural islands during the construction and operational phases. This is also supported by the statement that “the waters surrounding the artificial islands (including the water channels between islands) are very suitable for marinas and a variety of water sports venues including those for hosting local/international competitions.”(iii). In addition, whether human activities would be controlled from spreading to the currently undisturbed islands around the project site, thus threatening the survival of important species, such as the globally endangered and endemic Bogadeck’s Lizard (Dibamus bogadeki), has not been addressed.

5. The notion that “a comprehensive blue-green network will be planned on the artificial islands to … create a diverse range of flora and fauna habitats to enhance biodiversity” requires critical questioning as <u>urban greening does not necessarily equate conservation nor guarantee biodiversity enhancement</u>. Destroying natural habitats and replacing them with artificial and different habitats, as well as using disturbed scenarios as baselines for comparison of ecological conditions are extremely poor and scientifically indefensible practices from the conservation point of view. Such fallacious initiatives and practices should not be performed nor encouraged by the government, especially in such large-scale public works.

6. Although the transport plan on the website did not mention any connection to South Lantau, the report of the Study onTraffic, Transport and Capacity to Receive Visitors for Lantau – Feasibility Study (iv) recently released described the conceptual connection of KYCAI to North Lantau via road and rail links to Mui Wo and Discovery Bay. This transport plan may sabotage the Lantau closed road system, which is currently one of the most important lines of defence against incompatible development and vandalism in the environmentally fragile South Lantau, if the new railway or road links allow access to these connection points. As the proposal for KYCAI is very preliminary, such concepts may still be implemented in the future, and the impacts of KYCAI on South Lantau could not be ruled out.

<u>Actual Risks and Associated Costs of Climate Change Ignored</u>

7. According to the latest proposal of the government, the average height of KYCAI would be 7.5m (and up to 9m in certain areas) above sea level and this has taken into account the impact of climate change (v). However, according to the Sixth Assessment Report (AR6) released by the Intergovernmental Panel on Climate Change (IPCC) in March 2023 (vi), “Low-likelihood, high-impact outcomes could occur at regional scales even for global warming within the very likely assessed range for a given GHG emissions scenario. Global mean sea level rise above the likely range – approaching 2 m by 2100 and in excess of 15 m by 2300 under a very high GHG emissions scenario (SSP5-8.5) (low confidence) – cannot be ruled out”. AR6 also explicitly states that “Sea level rise is unavoidable for centuries to millennia due to continuing deep ocean warming and ice sheet melt, and sea levels will remain elevated for thousands of years (high confidence)”, and that “Due to relative sea level rise, extreme sea level events that occurred once per century in the recent past are projected to occur at least annually at more than half of all tide gauge locations by 2100”. However, these latest predictions and worst-case scenarios were apparently not considered in the design of KYCAI and the assumptions behind them as revealed by the recent response of the government regarding the concerns on climate change (vii).

8. Given the scale, environmental and financial costs associated with KYCAI, we strongly urge the authority to <u>include the latest best available evidence and prediction given in AR6 into consideration and apply a precautionary principle by considering the worst-case scenario</u> that may happen in the upcoming hundreds of years (at least up to 2300 as in AR6) when calculating the risk that would be brought about by the project. In addition, whether the alteration in hydraulics under intensified sea level rise and storm surges would impact <u>the nearby coastal areas</u> should also be addressed and made transparent to the public.

9. The authority states that carbon neutrality is one of the targets to be achieved through the KYCAI project. However, <u>the amount of carbon debt created during the construction stage, nor how would it be compensated has not been disclosed.</u> It is also unconvincing that the heat island effect could be effectively mitigated given the creation of such a large land mass with exceptionally high population density and narrow waterways among the islands. If the heat generated from the upstream of wind currents could not be dissipated, the temperature in the downstream land mass may need to be controlled by solutions that rely on even higher energy consumption.

<u>Procedural Imprudence and Injustice</u>

10. We opine that all public works, especially such a large-scale project that is highly controversial and involves enormous public interest, should set a decent example of procedural prudence and justice. However, the way the authority pushes forward the KYCAI project has been far from satisfactory, and posed hurdles for the general public to make informed decisions.

11. The environmental impact assessment of the project proceeds in a piecemeal fashion, with the entire project and its project profile being split into and accepted as three subprojects. This not only undermines the accurate assessment of the cumulative impacts of the overall project but also set a poor example that impairs the spirit of the environmental impact assessment process. The basic information given in the project profile was also extremely brief and did not properly inform the public on the details of the project (e.g. number, extent and arrangement of the artificial islands), which were only further disclosed in an incomprehensive manner during the PE stage.

12. The current PE process has not been conducted decently as the general public has not been adequately engaged and consulted since the very beginning. Apart from the obscure starting date of the consultation period and late availability of the public engagement materials, the general public does not have access to sufficient and complete information to assess the actual risks (e.g. climate change) and costs (e.g. environmental impacts and financial burden) of the entire project, of which the government admits that ample uncertainty still exists at this stage. This is particularly important as it is not known whether other phases of PE will be conducted when more facts and information are available.

<u>Inadequate Justification</u>

13. We opine that the actual land demand and supply should be cautiously calculated to avoid over-supply of land at unnecessary environmental costs due to overlapping planning intentions of various mega projects. With other land supply proposals (e.g. the Northern Metropolis) and existing solutions (e.g. brownfields) to be considered, the KYCAI should not be put forward.

We would like to reiterate that pushing forward such a megaproject without properly addressing, or even ignoring public concerns on the environmental, ecological, public health and safety impacts highly deviates from what civilized governance should be. It is also irrational to assume that environmental and ecological impacts, as well as risks from climate change, could be sufficiently solved by engineering solutions, and exclude a “no-go” option in the discussion and decision-making processes. We sincerely hope that the authority fulfils the responsibility of safeguarding our citizens’ and environmental well-being, and makes such a critical decision with due diligence.

Yours sincerely,

YUEN Yan Ling, Elaine
Conservation & Research Manager
Green Power

Yours sincerely,

YUEN Yan Ling, Elaine
Conservation & Research Manager
Green Power


i. Dennis, T. E., & Baxter, C. I. 2006. The status of the White-bellied Sea-Eagle and Osprey on Kangaroo Island in 2005. South Australian Ornithologist, 35(1/2): 47.

ii. Dennis, T. E., McIntosh, R. R., & Shaughnessy, P. D. 2011. Effects of human disturbance on productivity of White-bellied Sea-Eagles (Haliaeetus leucogaster). Emu-Austral Ornithology, 111(2): 179-185.

iii. Civil Engineering and Development Department. 2023. Major Planning Concepts. Kau Yi Chau Artificial Islands Website. Available online:  Accessed in: March 2023.

iv. Ove Arup & Partners Hong Kong Ltd. 2022. Study on Traffic, Transport and Capacity to Receive Visitors for Lantau – Feasibility Study (Agreement No. CE 8/2017(CE)). Executive Summary. Available online: Accessed in: March 2023.  

v. Government of the HKSAR. 202. 交椅洲人工島設計符合國際標準. Available online: Accessed in: March 2023.

vi. IPCC. 2023.Synthesis Report of the IPCC Sixth Assessment Report (AR6) – Longer Report.Available online: Accessed in March 2023.

vii. Development Bureau. 2023. 交椅洲人工島:充分考慮環境影響及氣候變化因素. Available online: Accessed in: March 2023.