1. The proposed reclamation project would significantly impact the critically endangered population of about 60 Sousa dolphins in the area by destroying their habitat. The report failed to properly address avoidance of sensitive habitats and minimization of reclamation scale. 2. The report contradicted itself on the blockage effect of reclamation, which would likely prevent dolphin movement between habitat areas. Dolphins cannot be trained to pass through the proposed navigation channel. 3. The mitigation measures proposed in the report were vague and lacked specifics on how impacts would be minimized or avoided. No concrete commitments were made to dolphin conservation.

1. Comments on EIA report for Kuokang Petrochemical Company’s Reclamation Project
by Samuel Hung, Ph.D., Chairman of Hong Kong Dolphin Conservation Society
Habitat Loss
1. The report completely ignored the significant impact of the huge amount of
habitat loss resulted from the massive reclamation. The reclamation site will be
situated in the middle of the critically endangered Sousa population, which
inhabited the narrow stretch of coastal waters in Eastern Taiwan Strait. The
potential habitat loss will probably be the major and last blow to the chance of
survival of this small population of about 60 dolphins, as it will destroy a
significant portion of their critical habitats for them to forage and move through
in order to have access to the entire population range. Also, the destruction of
benthic environment due to reclamation works (not just the reclamation site but
also the extended footprint away from the work site) will further decrease the
available food resources drastically for dolphins.
2. In Hong Kong, for any reclamation project being proposed, the project proponent
should first consider all the suitable sites during site selection processes (i.e.
avoidance), and most if not all projects will avoid any sensitive habitat, including
the high density area of dolphins. For example, the recent reclamation area for
the proposed Hong Kong-Zhuhai-Macau bridge has been relocated to a low
density area of dolphins, in order to minimize the impacts. If the site selection
process is not done properly, then the project will certainly be rejected without
consideration other aspects of impact assessment and mitigation measures.
Moreover, after a proper site is selected, the project proponent should try
diligently to minimize the reclamation site as much as possible (i.e.
minimization). This project did not show any of the common practices in an
EIA (avoidance and minimization), and therefore the impacts are not assessed
properly at all.
3. Due to the reasons mentioned above, I strongly suggested that this EIA report
should be rejected (or put on hold) at this point, until the habitat loss is properly
addressed, as this is the single most important impact in relation to dolphin
conservation issues. Other impact assessments and mitigation measures seem
to be irrelevant at this point if the habitat loss of dolphins is not properly dealt
with.
Blockage Effect
4. There is a major conflict of message presented in the report about the blockage
effect of the reclaimed land. On one hand, the report mentioned that dolphins

2. can move around the reclamation site since the water depth is still relatively
shallow. On another hand, the report suggested that dolphins may use the
700-m navigation channel to increase their chance of movement through the area.
First, the western edge of reclamation site is much further away from the
shoreline than the breakwaters at Taichung and Mialiao Harbours, and it is very
likely that dolphins will not move that offshore to go around the reclamation site.
So the reclamation site will likely block off any individual dolphin movement
between the northern and southern ranges of the population.
5. Second, it is quite a common sense to any marine mammal scientist that wild
dolphins cannot be trained to pass through a narrow channel in the wild, and
similar experiment has not been implemented anywhere in the world. In Hong
Kong, there was a small channel between the airport platform and Lantau Island,
and that area used to have access of dolphins before the reclamation of the
airport platform. After the reclamation, the channel that is about 1-km wide
was presumably still a dolphin habitat, but after crossing the channel hundred of
times by ourselves, we have never seen dolphins there. So even the channel is a
potential habitat for dolphins, the adjacent reclamation has effectively eliminated
that habitat for dolphins as well. Therefore, it is highly unlikely that dolphins
will use that 700m navigation channel adjacent to the Koukang reclamation site,
and they will not follow the “instruction” by the “trainers” to increase their
chance of moving through.
Mitigation Measures
6. It is very disappointing to see that the mitigation measures mentioned in the last
page were very vague and sketchy. They were not professionally done as there
were no specific details on the proper measures to deal with each impact, and
how effective those measures can be implemented in order to minimize or avoid
the impacts. Besides the commitment for more monitoring research, nothing
has been committed for dolphin conservation purposes in relation to all the
potential negative impacts arisen from the construction works and operation of
the facilities.