6. EIA (Environment Impact Assessment) for the landfill project
The future of the Awase Tidal Flat, Okinawa
Another EIA survey with strict scientific processes is needed!!
@@@@@By the Volunteer Group to Consider Okinawa's Tidal Flats
The EIS (Environment Impact Statement) was publicized for the landfill project at Awase tidal flat area. The EIS did not reflect the real conditions of natural habitats of the marine site concerned and is, therefore, insufficient.
The EIS did not include necessary environmental aspects properly for evaluation and assessment. Conservation measures mentioned within the EIS are based on ambiguous explanations and the reason why those measures are chosen is not clear.
Scientific explanations given for impacts on natural environment and conservation measures are not clear nor sufficient for implementing the project. We believe another EIA surveys should be carried out with more strict scientific processes.
(1) General Conditions of Tidal Flats in Okinawa Prefecture
Within Ryukyu archipelagos, large tidal flats are found mainly in central and southern parts of Okinawa Island. However, if all on-going development projects are to be implemented without modification, those large tidal flats will be lost forever. The above-mentioned EIS did not consider such conditions of diminishing tidal flats in Okinawa today.
The Okinawa Prefectural Government published gGuidelines for Conservation of Natural Habitats (Okinawa Island version)h in 1997. The main purpose of these Guidelines is to identify indicators to take actions for nature conservation.
The Guideline classified the major area of Awase Public Water Landfill Marine area as of the highest Rank I (areas for strict conservation measures). However, the EIS did not mention this fact that the area was classified as Rank I.
(2) Awase Tidal Flat
Awase tidal flat area - over 200 ha at low tide - is one of largest intertidal flats within Nansei Archipelago. The EIS did not consider this fact.
Avifauna
1.The Wild Bird Society of Okinawa has identified 11 orders, 33 families, 125 species (129 subspecies) of avifauna in Awase tidal flat and its environs. Among them, 30 species are identified as endangered/threatened. The EIS confirmed 8 orders, 20 families, 66 species which are only half of 125 species mentioned above.
2.The largest concentration of waterfowl in Okinawa Island can be found in Awase tidal flat area. This fact was not mentioned in the EIS.
3.Awase tidal flat and Yonaha Bay/Miyako Island are two largest wintering areas for Pacific golden plover (Pluvialis fulva) in Japan. This fact was not mentioned in the EIS.
4. It was confirmed that little tern (Sterna albifrons) breeds in the Awase area. Little tern is classified as a rare species in gThreatened Wildlife in Okinawah and as vulnerable in the Ministry of Environmentfs Red List. Awase and two other places have been identified as only natural breeding sites for this species within Okinawa Prefecture. Only several breeding sites are found throughout Japan for little tern, and therefore the species should be considered as being in the more critical condition than evaluated by the Ministry of Environment.
The EIS, however, did not confirm the breeding of little terns at the site. Thus there is no mention of the impact on little terns.
5.Although the mating-related activity of Kentish plover (Charadrius alexandrinus dealbatus) was recorded at the site, no further research was carried out then. Therefore, there was no evaluation of impacts on breeding activities of Kentish plovers. As regards the breeding of overall birds (waterfowl), the target area of the EIS was limited to the planned landfill site. Since it is clear that there shall be impacts beyond the landfill site, an impact assessment should be carried out to include the environs.
Benthos
Seagrass beds are natural habitats with high biodiversity. According to a supplementary EIA research carried out by the central government, more than 210 species of benthos were identified. 25 threatened shellfish species were included (gWWF Japan Scientific Reporth).
Regardless the fact that more than 210 species of benthos were identified by the supplementary research, there was no impact assessment on tidal flat areas nor seagrass beds based on its findings. A local newspaper reported that the findings did not come up in time for finalizing the EIS. But the understanding of local fauna and flora is the basic need for any impact assessment. The EIS is tremendously insufficient without taking into consideration of the research result which identified over 210 species. The explanation that the research result did not come up in time for the EIS is no way convincing and therefore unacceptable.
Seagrass
1. As regards seagrasses, the EIS said: git is difficult to avoid or abate the impacts of landfill processes (on seagrass beds). Since the role of seagrass beds as ecosystems is important, the loss of seagrass beds by landfill processes is significant.h The transplanting of seagrass beds is being planned.
However, the planned transplanting area is already natural seagrass beds area and next to the landfill site. In addition, the dredging is also planned nearby for assuring cruising routes.
Therefore, it is reasonable to envisage impacts on the transplanting site by landfill and dredging processes as well as the very existence of the landfill site and cruising routes nearby. However, there is no mention of conservation measures considering those impacts.
2. Regarding transplanting, Ryukyu-amamo (Cymodocea serrulata) and Bouba-amamo (Syringodium isoetifolium) are to be transplanted to a new site. The reason why these two species were chosen among eight species identified at Awase marine area was not clarified.
3. Distribution pattern of seagrasses was divided into two areas: area with over 50 % coverage and area with less than 50 % coverage. The seagrasses will be transplanted into the scarce area (with less than 50 % coverage). Since it will be transplanting into the scarce area, the EIS concluded that there will be no large-scale disturbance on natural environment of the area. However, it is clear that the coverage of seagrasses differs according to species and seasons. Seagrassess also develop underground stems, and therefore the survey of their coverage is not sufficient. It is inappropriate to evaluate seagrass conditions by coverage without considering species, season and underground parts.
Blue mud hopper (Tokage-haze in Japanese; Scartelaos histophorus)
At maximum 10 individuals of blue mud hoppers were identified within 200 m2 mudflat area while the total area of 49 ha of intertidal flat areas with sands and gravel will be lost by the reclamation.
Blue mud-hoppers were noticed as representing species of intertidal flat areas which are to be lost due to the landfill project. Mudflat areas are not reclaimed and representing only 0.0004 % of intertidal flat areas with sands and gravel. Blue mud hoppers are, therefore, not appropriate to represent would-be lost intertidal flat ecosystems. Another representing (noticeable) species should be chosen among wildlife, which actually live within intertidal flat areas with sands and gravel.
Other important (threatened) species
1. Dugong (Dugong dugong) is classified as endangered species both by gDatabook on Rare Wild Aquatic Species in Japan (compiled by the Fishery Agency)h and the Red List by the Mammalogical Society of Japan. According to a research by the Dugong Network Okinawa, a dugong was reported near Hisataka Island within Nakagusuku Harbour marine area (July 1999). A body of a dugong was washed ashore at Sashiki area (January 1987).
Seagrass beds provide feeding sites for dugongs. The seagrass bed area at Awase marine area is one of largest in Okinawa Island. Feeding signs were reported in Awase marine area in 1994. The EIS for the area should include a research on dugong (traces). However, no survey on dugong was carried out.
4. Although the ecological knowledge of Kubiremidoro (Vaucheria constricta ; Endangered by the Ministry of Environmentfs Red List; Threatened both by the Fishery Agency and Okinawa Prefecture) is scarce, it took only three months from identifying the species to finalizing conservation measures (in the EIS). Conservation measures without considering the life cycle of V. constricta is not convincing. According to the one of conservation measures, the species will be transplanted to another existing habitat (Yakena area of Kim Bay). However, there is no mention of genetic or habitat disturbance on V. constricta at Yakena area as the result of transplanting.
For establishing techniques to increase V. constricta, the technique development scheme will be introduced. However, mitigation methods including transplanting should be considered only after establishment of such techniques.
Table 1. List of the endangered species which were recorded by environmental survey and supplementary
survey of the environmental assessment.
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