kmike

I have followed this project since the consultation began.  

The principal consideration has been the threat to White-bellied Sea Eagle. The survey work has been done by a highly skilled birder and CLP have shared their findings.  No WBSE at all were recording in the project area, and additional survey work showed that adult are very site loyal.  the biggest threat is to young birds, especially newly fledged birds, especally if the nest is close to the windfarm and is line of sight as they are learning to fly.

I have raised the point about night migrants in a recent meeting and we should raise this again.  

Our data is of course freely available to anyone who cares to look at our annual reports and the Avifauna. We charge only to cover administrative costs when we are asked to organize additional data for commercial projects.

Article based on my submission to the study brief is attached below. At the time I informed CLP that this was the minimum criteria against which HKBWS would assess the EIA.

Bulletin 202
Conservation News
Wind Farms Plans Threaten Hong Kong’s White-bellied Sea Eagles

Wind farms - in Hong Kong and worldwide
Hong Kong’s White-bellied Sea-Eagles are under threat from the proposed development of two large-scale wind farms. The 90 planned turbines are huge - the blades are 90m in diameter and will rotate around a hub on a 70m tower. This gives a maximum height for the spinning blades of 115m above sea level. These wind farms are proposed for an area east and south of the Ninepins, close to Sai Kung and Clearwater Bay, and another for either the same area, or the West Lamma Channel, close to Lamma Power Station.

There has been growing interest worldwide and in Hong Kong in the issue of greenhouse gases and global warming, and how both might be reduced by replacing fossil fuel-burning power stations with renewable energy sources.  In order that Hong Kong is seen to be doing its bit, the Environmental Protection Department (EPD) has required both the local power companies to install experimental wind turbines – one is already in place on Lamma and another, set to be located at Hei Ling Chau, is going through the EIA process. EPD is also encouraging the introduction of commercial scale wind turbines in Hong Kong by guaranteeing the power companies a higher rate of return for electricity generated from renewable sources. Each field is projected to generate approximately 1% of Hong Kong’s energy needs.

This all sounds great. Unfortunately it is not that simple.  There is a growing concern and a strong body of credible evidence from around the world that wind farms are causing the deaths of many birds, especially eagles. Information is available on the web from as far afield as Japan, California, Spain, the UK and Norway of a significant numbers of eagles being struck and killed by rotating blades on wind turbines.  A variety of information is available on the Internet. Some are listed below:

Wind farms & eagles worldwide: http://www.birdforum.net/showthread.php?t=27198
Wind farm cancelled in Scotland: http://www.birdforum.net/showthread.php?t=69139
White-tailed Eagles decimated in Norway: http://www1.nrk.no/nett-tv/klipp/193197
Bird genocide at wind farms: http://www.iberica2000.org/Es/Articulo.asp?Id=1188
Assessment of mortality reports: http://www.iberica2000.org/Es/Articulo.asp?Id=1223
Wind farms and greenhouse gases: http://www.iberica2000.org/Es/Articulo.asp?Id=1186


Wind farms and eagles in Hong Kong
Hong Kong’s White-bellied Sea Eagle population of about 10 pairs is the most important in China. Elsewhere, adult birds are shot and their nests raided for their eggs, usually by fishermen.  In Hong Kong all birds and their eggs are protected, both by the law, and by the fact that even with the fishing industry in crisis our fishermen do not need to shoot eagles to survive!

Unfortunately, the proposed locations for the wind farms are close to areas that are traditional strongholds of the eagles – Sai Kung (specifically, to the east of the Ninepins) and southern waters of Hong Kong (West Lamma Channel).  These sites have been selected because they supposedly offer the potential for commercially-viable winds in areas that do not interfere with shipping lanes, aircraft flight paths or existing infrastructure (such as undersea cables and pipelines).  The upcoming Environmental Impact Assessments are intended to establish whether the proposed wind farms are likely to cause any environmental or ecological impacts. Unfortunately no mention is made of the need to study the potential impacts on White-bellied Sea Eagles in either the project profiles submitted by the project proponents, or in the study briefs (which determine what information the EIA should include) issued by the Environmental Protection Department. These documents can be found online at the EPD website at:

Southeastern Waters (near Ninepins in Sai Kung) – 50 turbines of up to 3MW capacity
Project profile:     http://www.epd.gov.hk/eia/register/profile/latest/esb-146.htm
Study brief:          http://www.epd.gov.hk/eia/register/study/latest/esb-146.htm

West Lamma Channel or East Ninepins (Sai Kung) – 40 turbines of 2.5MW capacity
Project profile:    http://www.epd.gov.hk/eia/register/profile/latest/esb-151.htm
Study brief:        http://www.epd.gov.hk/eia/register/study/latest/esb-151.htm


How can HKBWS make use of the EIA to protect White-bellied Sea Eagles?
The next section quotes the detailed requirements of the ecological assessments as stated in the study briefs for the two projects. In this section we will include some of the issues we consider to be relevant (in italics) and raise them below the specific point laid out in the study brief. The intention is to outline key considerations in relation to White-bellied Sea Eagles and suggest the information that we believe is necessary to assess the potential impact on this species from these projects.

2. Objectives of the EIA study
     
(iv)    to identify and quantify any potential loss or damage and other potential impacts to ecology and fisheries resources, flora, fauna and natural habitats and to propose  measures to mitigate these impacts;

•    How have wind farms (especially coastal wind farms) impacted eagle populations in other parts of the world?

(xiii)    to design and specify environmental monitoring and audit requirements to ensure the effective implementation of the recommended environmental protection and     pollution control measures.

•    What solution is proposed to ensure that birds killed by rotor collision are effectively recorded in a marine environment?

3.4.2 Ecological Assessment (Terrestrial and Marine)
3.4.2.4 The assessment shall include the following major tasks:

(i)      review the findings of relevant studies/surveys and collate the available information regarding the ecological characters of the assessment area;

•    How many WBSE territories are there in Hong Kong?
•    How large are the territories of breeding pairs of WBSE in Hong Kong?
•    Is the foraging range the same size as the breeding territory?

(ii)    evaluate information collected and identify any information gap relating to the assessment of potential ecological impact;

•    How many breeding territories overlap with the proposed wind farm sites?
•    How often do adult birds wander outside these territories?
•    Where do juvenile and subadult birds go once forced out of their parents’ breeding/foraging territories?
•    Is the KFBG radio tracking study of immature WBSE useful for determining the behaviour of subadult WBSE?

(iii)   carry out ecological field surveys and investigations to fill in the information gaps identified in Sections 3.4.2.4 (ii) above and fulfil the objectives of the EIA study.     The field surveys shall include . . . avifauna, in particular migratory birds.  . . . and the avifauna surveys shall cover at least 9 months covering March to August.

•    Why are resident species (which are of most concern) not emphasized by the brief?
•    What do WBSE (which is a resident species) do between August and March?
•    Why is this period excluded?
•    At what height do WBSE forage?

(iv)     establish the general ecological profile of the Study Area based on data of relevant previous studies/ surveys and results of the ecological field surveys, and taking into consideration the seasonal variations, and describe the characteristics of each habitat found; major information to be provided shall include:

(b)     habitat maps of suitable scale showing the types and locations of habitats/species in the Study Area with special attention to those with conservation interests, including but not limited to the following:

        Ø        avifauna, in particular migratory birds; and

•    Why not resident White-bellied Sea Eagles?
•    How many WBSE breeding/foraging territories overlap with the proposed wind farm sites?
•    How many suitable breeding sites for WBSE occur within the study area?

        Ø        any other habitats/ species identified as having special conservation interest by this EIA study.

•    NB: the Hong Kong population of WBSE is the most important in China

    (e)     species found that are rare, endangered and/or listed under local legislation,  international conventions for conservation of wildlife / habitats or red data books;

•    NB: WBSE is a Class II protected species in China.

    (f)     investigation and description of the existing wildlife uses of the various habitats with special attention to those wildlife groups and habitats with conservation interests, including but not limited to . . .  avifauna in the context of the proposal;

•    What is the actual/potential utilization of the study area by WBSE?
•    NB: It seems highly unlikely that monthly transect surveys will generate sufficient data to provide a meaningful answer to this question.

(vi)    using suitable methodology and considering also other works activities from other projects reasonably likely to occur at the same time, identify and quantify as far as possible of any direct, . . . indirect (e.g. changes in flight path), on-site, off-site, primary, secondary and cumulative ecological impacts such as destruction of habitats, reduction of species abundance/diversity, loss of feeding grounds, reduction of ecological carrying capacity, habitat fragmentation, and in particular the following:

Ø      impacts to . . .  avifauna during operational stage due to rotation of the wind turbines, noise produced by the wind turbines and the glare due to reflection of sunlight;

•    What is the potential area of lost WBSE territory from this and similar installations (especially if both go ahead at the Ninepins)?
•    What other methods might be used to obtain more accurate data about the movements of both adult and juvenile birds outside established territories?
•    Are these methods consistent with global best practice?
•    What is the likelihood of rotor collisions on a) adults whose territories include one or more wind farms and b) wandering adults and sub-adult birds?
•    What would be the impact on the population of losing one or more birds per annum to collision-derived fatalities?

(vii)   evaluation of ecological impact shall be based on the best and latest information available during the course of the EIA study, using quantitative approach as far as practicable and covering construction and operation phases of the Project as well as the subsequent management and maintenance requirement of the proposals;

•    What are the likely impacts to the Hong Kong populations of WBSE from one or more fatalities per year to a) adult and b) subadult birds?

(viii)     evaluation of significance and acceptability of the ecological impacts identified using criteria in Annex 8 of the TM;

•    Are these impacts acceptable in the context of the protected status in China of WBSE and the importance in China of the Hong Kong population.

(xiii)   review of the need for and recommendation for any ecological monitoring programme required.

•    What monitoring measures are proposed to assess the ongoing operational phase impacts of the wind farm on Hong Kong’s WBSE population?

Another important point to raise is one of the most important aspects of the process for assessing environmental risk – the Precautionary Principle. This principle states that if you do not know what the impact of your project will be on a given habitat or species, you should not proceed in order to avoid the risk of causing damage due to unforeseen circumstances.  Bearing this principle in mind HKBWS will strongly challenge any EIA assessment for these wind farms that does not provide adequate answers to the questions raised above.  

Cheers
Mike