根據前濱及海床（填海工程）條例第6節，我對5月8日憲報第3319號公告描述的填海工程提出了正式反對，原文為英文。簡單地說，填海和為了飛航安全而訂立的航海管制區，將會令龍鼓水道可航行海面大幅縮窄一半或以上，影響通過此處前往珠三角各地、每年數百萬人次計的乘客的生命安全。提出反對的限期是7月8日。
To: Director
of Lands
From: Lam
Chiu Ying
Adjunct
Professor
Department
of Geography and Resource Management
Chinese University
of Hong Kong
Subject: Objection
to the undertaking described in Schedule of G.N. 3319
Date: 6
July 2015
The Objection
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).
3.
Numerous
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 Hong Kong,
especially those living in Tung Chung and along Castle Peak Road between Tuen Mun and
Tsuen Wan.
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. “D1998” 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. “D2023” 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 River Port). 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.
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 Lung Kwu Chau Marine
Park 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 Urmston Road
in the area marked with a black circle in fig. 1.
 |
Fig. 1 Marine traffic affected by the proposed reclamation. Blue lines show present routes; orange lines, revised routes of vessels departing from SkyPier after reclamation; brown line, container ship routes; red line, river boat routes. For illustration purpose, not for navigation.
|
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 River
Port at Tuen Mun, merchant vessels
travelling to Guangzhou
Port 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.
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.
Conclusions
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
rise too.
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
