To: Director of Lands
From: Lam Chiu Ying
Department of Geography and Resource Management
Subject: Objection to the undertaking described in Schedule of G.N. 3319
Date: 6 July 2015
1. In response to Gazette Notice 3319 dated 8 May 2015, this is to lodge a formal objection to the undertaking described in Schedule of that Notice, under section 6 of Foreshore and Sea-bed (Reclamation) Ordinance Cap. 127.
2. I have travelled and shall travel to and from Macau 澳門, Zhuhai 珠海, Shekou 蛇口, Furong 福永, Fumen 虎門, Guangzhou 廣州 and other destinations in the Pearl River Delta 珠江三角洲. The routes to these destinations pass through
Urmston Road, the sea channel with deep
draught off the coast of Tuen Mum and Lung Kwu
Tan, to the north of Hong Kong International Airport (HKIA).
Hong Kong citizens also travel to these
destinations. We have an established
right of safe passage through this sea channel.
4. It is the duty and responsibility of the HKSAR Government to protect the lives of its citizens by ensuring that marine traffic in the area is safe.
5. The proposed reclamation would greatly reduce the navigable width of this sea channel. It would increase substantially the risk of maritime accidents (including collisions and capsizes) and the risk to the lives of passengers heading for the above-mentioned destinations.
6. We are particularly mindful of the risk of maritime accidents after repeated occurrences of capsizes in
Hong Kong and
elsewhere in the world. The Lamma Island
tragedy of 2012 is a poignant reminder to Government that maritime safety
cannot be taken for granted in Hong Kong.
7. I fear for my safety and the safety of all who travel through Urmston Road if the proposed reclamation takes place, owing to the combined effects of narrower channel (paragraph 13), diversion of SkyPier traffic (see paragraph 15) and projected increase in ship traffic to Shekou Container Terminals.
8. I and fellow travelers consider that our established right of safe passage through the sea channel would be seriously compromised by the proposed reclamation.
9. Another consequence of the proposed reclamation is the increased risk of marine pollution in the form of oil leakage after collisions and capsizes, which would affect all residents of
especially those living in Tung Chung and along Castle Peak Road between Tuen Mun and
10. We object to the proposed reclamation in the absence of any published, in-depth, professional evaluation of the cumulative risk of maritime accidents and loss of lives as well as that of marine pollution, engendered by the proposed reclamation.
11. The Government is also reminded that, if the reclamation goes ahead in spite of being warned about increased risk to the safety of marine navigation and human lives, it would be liable to public outcry and eventually hefty claims for compensation arising from alleged “dereliction of duty” in the unlucky event of fatal accidents occurring in this sea area.
The Increased Risks of Maritime Accidents and Marine Pollution
12. The gravity of the issue is explained below with the help of an illustrative diagram (fig. 1). The base map is derived fro G.N. 3319. “D
1998” marks the position of buoy D in
Marine Department Notice No. 65 of 1998 dated 4 May 1998, which designates the
northernmost position of the “no go” restricted marine zone to protect aviation
safety. “D 2023” marks the inferred position of a
similar buoy to designate the new northernmost point of the restricted marine
zone of the expanded airport after reclamation.
13. The distance between Buoy D and the
River Port is
taken to represent the width of the navigable channel on and near Urmston Road
(assuming that vessels could sail right next to the ). From fig. 1, it is immediately evident that, if
the proposed reclamation goes ahead, the width of the navigable channel
would be reduced by HALF. River Port
14. In practice, bigger vessels have to maintain a safe distance from the coast. If this margin is taken off the “navigable channel”, then the percentage reduction of the width of the navigable channel after reclamation would be even severe. The impact on maritime safety is therefore of major concern and requires in-depth, professional evaluation.
15. A second relevant point is the change in routes of vessels leaving SkyPier on the airport island after the reclamation. At present most if not all of the vessels would sail south of D2023. After the reclamation, for the protection of Chinese White Dolphins, they have to avoid Sha Chau and
and so could no
longer use the existing route sandwiched between Sha Chau and HKIA. They will divert northward, turn left to
enter Urmston Road north of D2023
(to avoid the airport restricted zone), and then sail round the perimeter
of the Marine Park before joining the present routes. There will be increased traffic from
SkyPier on Lung Kwu Chau Marine
Park Urmston Road
in the area marked with a black circle in fig. 1.
16. Thirdly, the same applies to ferries heading for
Pearl River delta destinations
from Hong Kong Macau Ferry Terminal and Hong Kong China Ferry Terminal. They would all have to sail north of D2023,
instead of having some leeway to the south now.
Thus all would be squeezed through the black circle in fig. 1,
resulting in a higher density of traffic there.
17. Fourthly, the same applies also to numerous river cargo vessels bringing supplies to the
Port at Tuen Mun, merchant vessels
travelling to as well as container
ships visiting Shekou Container Terminals. After the reclamation, they
would also be squeezed through the same bottleneck, increasing traffic
density even further. Guangzhou
18. Finally, according to the statistics of Shekou Container Terminals Ltd, the traffic volume of SCT Terminals in TEUs increased by 51% between 2009 and 2014. The amount of container ship traffic is projected to increase significantly and quickly in the next decade or so. This aggravates further the magnitude of the maritime safety problem at the black-circle bottleneck.
19. Part of the reason for the navigable channel becoming very narrow is the need to safeguard aviation safety by designating a “no-go” marine restriction zone around the expanded HKIA. Thus it is a situation in which maritime safety is traded off for aviation safety. However, there is no a priori reason why aviation safety should prevail over maritime safety.
20. While maritime safety is a safety issue of critical importance (as explained above), the public is not aware of the results of any in-depth, professional evaluation conducted by Government regarding the increases in the risk of maritime accidents and associated issues like passenger safety and marine pollution.
21. The proposed reclamation and the need to provide marine restricted zones to safeguard aviation safety will result in a reduction (by half or more) in the width of the navigable channel on and around
Urmston Road. Maritime safety inclusive of passenger safety
would be compromised to a very significant degree. The associated risk of marine pollution would
22. The problem is aggravated by the diversion of all SkyPier ferry services into this narrow channel as well as the projected increase in container ship traffic.
23. Life should be the foremost concern of HKSAR Government and the precautionary principle definitely applies.
24. Maritime safety must not be compromised by economic consideration. It also should not be eclipsed by aviation safety consideration.
25. In the absence of any in-depth, quantitative, professional evaluation of the life-threatening risks arising from the proposed reclamation, Government would be acquiring unwarranted liability by letting the reclamation to go ahead in spite of being warned about the risks to shipping and to human lives.
26. I reaffirm the objection to the proposed reclamation and strongly recommend to Government that no permission should be given at this point in time.
Lam Chiu Ying 林超英