去年7月，根據前濱及海床（填海工程）條例第6節，我對第三條跑道的填海工程提出了正式反對（註1），主要論據是填海後機場的海上交通管制區大幅擴充，龍鼓水道的可航行海面大幅縮窄，增加該處的海上安全風険，11月地政總署給了回應，但是我拒絕撤回反對，原因有三：
(1) 公眾從未見過相關海上交通影響評估報告
(2) 機管局預測未來海上交通時，沒有計算內地海港如蛇口貨櫃港的快速增長
(3) 高船體的船隻對航空安全的影響未有處理（參考註2）
遞交地政總署的文件全文見下，部份圖因為地政總署把顧問報告列為機密文件，所以加以覆蓋，以表尊重。
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Objection Number: LD3RS2
TO: District Lands Office, Islands
Lands Department
19/F, Harbour Building
Email leissd@landsd.gov.hk
G.N. 3319
FORESHORE AND SEA-BED (RECLAMATIONS)
ORDINANCE (Chapter 127)
(Notification under Section 5)
Expansion of Hong Kong International Airport
1. I
refer to your letter dated 14 January 2016 (your reference: (7) in LD DLO/IS
FSRO/3RS/02). I appreciate the explanations given in the Annex to the
letter and the copies of consultant reports attached. Those reports have
enabled me to understand much better the technical issues involved, which has
strengthened my position in objecting to the reclamation.
2. I
maintain the objection I submitted on 6 July 2015 and my Further Comments
submitted on 22 November 2015. The reasons are elaborated below.
Original Objection
3. The
key point of my original objection dated 6 August 2015 isincreased risk of
maritime accidents and consequently that of marine pollution.
The increased risk is indeed confirmed by chapter 8 “2030
Benchmark Year Marine Traffic Collision Risk Modelling Results” of Marine
Traffic Impact Assessment Report Final Study Report March 2015 (“MTIA
Report” or “the Report”). On page 82, it specifically recognizes that the
Three-runway Project would increase the number of maritime collisions
by 1 per year.
4. In
section 8.7 “Risk Acceptability”, the consultant’s conclusion that the
increased risk was acceptable was based on a “clear and unambiguous guideline
on risk acceptability” (p.83) spelt out in chapter 12 “Hazard Assessment” of
the EIA Ordinance Technical Memorandum (EIAO TM) and the associated Annex 4“Criteria for
Evaluating Air Quality Impact and Hazard to Life” (full text
given in Appendix 1). On detailed examination of the Report, it is
revealed that the consultant has made a serious, fundamental mistake in the
application of the guideline.
5. The
original figure in EIAO TM (fig.1) and the figure presented by the consultant
on p.84 (fig. 2) are shown side by side below. According to EIAO TM, the
scale on the left-hand side is the frequency (F) of accidents with N or more
fatalities per year. It refers to the number of accidents (“collisions”
in the present case). It has nothing to do with any number related to the
population. But in the Report, the label was simplified to “frequency per
year” in the Report and the value of “frequency” was derived by an un-orthodox
algorithm. As will be explained later, the data points plotted in the
lower left-hand corner of fig.2 were incorrectly placed and sere indeed wrong
by a wide margin of several orders of magnitude.
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| Fig. 2 MTIA Report figure |
6. According
to pp. 83-84 of the Report, out of all HKSAR maritime collisions
a. 1 fatality occurred in 0.3% of collisions
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b. 2 fatalities occurred in 0.1% of collisions
c. 3-10 fatalities occurred in 0.1% of collisions
d. 10-50 fatalities occurred in 0.1% of collisions
7. Expressed
in terms of N fatalities or more:
a. N=1 in 0.6%
of collisions
b. N=2 in 0.3%
of collisions
c. N=3 in 0.2%
of collisions
d. N=10 in 0.1%
of collisions
8. The
Three-runway Project is responsible for increasing the number of collisions
by 1 per year (see paragraph 3). Combined with the
probability figures in paragraph 7, the frequencies of collisions per year
corresponding to the various numbers of fatalities arising from the
Three-runway Project are:
a. F=0.6%=6 x 10-3 for N=1
b. F=0.3%=3 x 10-3 for N=2
c. F=0.2%=2 x 10-3 for N=3
d. F=0.1%=1 x 10-3 for N=10
9. In
the Report, on p. 84, the consultant wrongly adopted “37.1 collisions” in
assessing the acceptability of risk arising from the Project. But an even
worse and fundamental mistake was made when the consultant divided the
frequency figures by a totally irrelevant figure of 12 million (the number of
people transiting the Focus Area aboard vessels). Their pretext is “to
create the risk profile of the fatality potential”, which is an un-defined
phrase carrying no established sense. It is merely a jargon to frighten
off non-mathematicians and non-statisticians. By introducing the
irrelevant denominator, the end result is that the derived figures are NOT what
the clearly defined term “frequency of accidents” means. If not for the
wrong adoption of “37.1” ,
the derived figures would have been SIX ORDERS OF
MAGNITUDE OFF.
10. Following
the correct approach explained in paragraphs 6-8, the correct positions of the
data points plotted in the official figure in EIAO TM Annex 4 Societal Risk
Guidelines for Acceptable Levels are shown in fig. 3 (next page).
11. It
is abundantly clear from fig. 3 that the additional risk arising from the
Three-runway System falls within the “UNACCEPTABLE” zone. This confirms
the concern which I expressed in my original submission dated 6 August
2015. Since my concern has been validated by the consultant’s own data
and the criterion it has adopted viz. EIAO TM Societal Risk Guidelines, I
am therefore in no position to withdraw my original objection to the
reclamation associated with the Three-runway System.
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Fig. 3 Additional risk arising from the Three-runway System
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12. My
“Further Comment No. 1” dated
22 November 2015 is also validated because only with the information
available in the MTIA Report is it possible to discover that the consultant has
made a gross mistake in the assessment of the acceptability of additional risk
to maritime safety arising from the Three-runway System.
Further Comment No. 2
13. With
regard to Further Comment No. 2, it is observed that p. 48 of MTIA Report
made no reference to any Chinese source on the projected
growth in ocean-going traffic from Chinese Mainland ports upstream in the Pearl River estuary, in particular the Shekou
Container Terminals (SCT). In Table 3.3 “Summary of Stochastic Forecast
Increases (2013 to 2030)”, under “Ocean Going”, the “Upper Bound” and “Lower
Bound” were set at 66% and 61% respectively. But as stated in my original
submission, the traffic volume of SCT increased by 51% between 2009 and 2014
alone. The consultant’s figures were therefore most likely a
significant underestimate.
14. Furthermore,
because goods carried by these ocean-going vessels in transit through Hong Kong
waters are not captured by Hong Kong Port statistics, no Hong
Kong data source can remedy this shortcoming. The
failure of the consultant to obtain reliable data from the Mainland side rendered
its projection for Ocean Going vessels invalid, and consequently, its
simulations and risk assessments invalid. Therefore my Further
Comment No. 2 stands even more strongly with additional information from the
MTIA Report.
Further Comment No. 3
15. With
regard to Further Comment No. 3 which concerns the mutual interference between
maritime safety and aviation safety, MTIA Reports affords me an opportunity to
examine closely the setting up of the HKIA Approach Areas (HKIAAA), which as
you have mentioned in your letter dated 14 January 2016, “is an area
established in the vicinity of the airport island to safeguard flight
safety”. Fig.4 shows fig. 2.3 from MTIA Report, with the addition of four
measurements of the distance between runway thresholds and the corresponding
HKIAAA boundary segments.
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16. The
“safeguard” distances for the northern runway are 2.1 kmon both the
eastern and western sides. They are correspondingly only 62% and 58% of
their counterparts on the middle runway. The eastern extent of the HKIAAA
for the northern runway has been curtailed in order to avoid breaching marine
safety in Urmston Road
17. Maritime
safety has been nominally ensured by the HKIAAA delineation shown in fig. 2.3
of MTIA Report, allowing high airdraft vessels to travel on Urmston Road
18. This
critical safety issue has not been addressed by any report published by the
Airport Authority so far. In the absence of any conscious effort by the
due authority to quantify the additional risk due to the shortened safeguard
distances, it is premature to conclude that the increased risk of
aviation accidents is within acceptable levels. Therefore my
Further Comment No. 3 stands even more strongly with information available in
the MTIA Report.
Additional Observations
19. The
north-western corner of HKIAAA is artificially cut(see fig. 4 above) owing
to the limitation of the Hong Kong –
Mainland border. It has negative impact on aviation safety. The
consultant recognized this issue in section 5.4 on p. 66 of MTIA Report.
The Report indeed recognized that derrick lighters with airdraft exceeding 30
metres would cross the area about once a day. But the consultant was
unable to offer any means to ensure that no vessel with such airdraft would cut
corners and infringe aviation safety at this sensitive area (section 10.2.3 ,
p. 95-98). The consultant has merely left it as “subject to
further study and under Environment Permits Conditions” (p.
98). Thus this remains an unresolved safety issue. The
reclamation cannot go ahead with such critical safety issue hanging in the air.
20. The
MTIA Report explicitly said that it did not cover marine traffic impact
“relating to Mainland Anchorages (Lantau Island No. 2 Anchorage and Anchorage Lantau Island Hong Kong – Shenzhen consultations. Therefore
this remains an open question with no guarantee of success in the
resolution of the maritime-aviation safety issue. This being the
case, there is no guarantee that aircraft can land safely on the northern
runway from the west, which means that the purpose for which it is built cannot
be realized. In view of this, the reclamation cannot go ahead.
Conclusion
21. My
objection to the proposed reclamation under the Foreshore and Sea-bed
(Reclamations) Ordinance (Chapter 127) continues to stand, together with the
three Further Comments.
22. My
objection is firmly based on:
a. Unacceptable
societal risk which has been validated by MTIA Report data
b. Gross
mistake in the consultant’s assessment of acceptability of accidents with
fatalities
c. Failure
of MTIA Report to factor in growth in ocean-going traffic based on reliable
Chinese sources and significant underestimate compared with information from
Shekkou Container Terminals
d. Aviation
safety in relation to the northern runway has been compromised after priority
being given to maritime safety, to an extent not yet quantified properly
e. Aviation
safety issue associated with the north-western corner of HKIAAA which has
remained unresolved
f. Open
question about maritime-aviation safety issue associated with Lantau Island
Anchorage No. 2, which requires Hong Kong –
Shenzhen consultation and coordination, of which no evidence has been presented
to date.
23. I strongly urge you as a matter of
due diligence to engage a neutral expert of high standing in statistics, with
no vested interest in the Three-runway System, to examine critically the
assessment done by the Consultant of the acceptability of additional risks
arising from the Three-runway System, in particular the contents of section 8.7
of MTIA Report. Before this is done, presenting the proposed reclamation
to Executive Council would not be good governance and is subject to judicial
review.
24. I sincerely hope that you would
treat SAFETY as top priority in dealing with this matter. Economic
consideration must not interfere with your decision.
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Appendix 1
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END
