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3.Opinion and Requests Regarding Protection of Awase Tidal Flat, Okinawa,
and Problems with the Associated Seagrass Transplanting Project
by WWF Japan
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To: Mr Koji Omi, Minister of State for Okinawa and Northern Territories Affairs
From: Mr Michio Hino, Director, World Wide Fund for Nature Japan (WWF-Japan)
Date: Monday, 10 June 2002
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Dear Minister,
We hope you will accept our best wishes for your continued health and good fortune, and we would also like to express our gratitude for your growing understanding of our organization and its activities.
One of the important pillars of our organization’s work is protection of biological diversity in the Nansei Archipelago, which has been chosen as one of WWF’s Global 2000 Ecoregions ? areas of the Earth that possess diverse and important ecosystems. Another is protection of wetlands, based on the Ramsar Convention, and particularly of tidal flat wetlands.
Awase tidal flat in Okinawa is an important staging and wintering site for migratory birds, and has a large area of seagrass beds, known for their diversity of bottom-dwelling life, and thus is an important area from the point of view of biological diversity protection. However, the tidal flats and seagrass beds at Awase are in danger of being destroyed by the “Okinawa City East Beach (Awase Region of Nakagusuku Bay) Development Plan.” In December 2000, WWF-Japan submitted a “Request for the Conservation of Awase Tidal Flat” to the relevant government agencies, but subsequently the landfill plan went forward, and in March of this year construction on part of the project was officially begun. Therefore, our organization has decided to submit another opinion statement.
With respect to seagrass beds at the site, the developing agencies have undertaken an experimental transplanting project as a mitigation measure, and based on a decision in February 2002 that “Results of the experimental transplanting project are favorable, and mechanical transplanting will be possible, meaning that solutions to environmental problems are for the present being found,” decided to push the landfill project forward, starting in March with part of the actual work.
However, experts both inside and outside Japan have leveled criticism at the seagrass transplanting project’s original concept, techniques, methods, and present evaluation. Based on the reasons elaborated below, WWF-Japan believes that the results of this experimental transplanting project cannot be called favorable, and that a look at the reality will reveal that, on the contrary, that there is a good possibility that high quality seagrass bed environments at both the source seagrass site and at the transplanting site are being degraded.
In addition, the land-use plan for the landfilled land to be constructed at Awase tidal flat is a relic of the 1980s, and prospects for occupation by hotels and offices of the planned resort and business districts and predictions for economic stimulation, etc., are all excessive, and it is thought that there is an exceedingly small chance that they will be borne out in reality.
Thus, WWF-Japan makes the following three requests to the relevant agencies and organizations, and asks that they be implemented.
1. Clearly explain the concepts, techniques, methods, present analysis, monitoring time frame and methods, and process of evaluation of the results of the developer’s seagrass transplanting project to ordinary citizens, fishermen, environmental conservation organizations and experts.
2. Clearly explain what conservation measures will be taken with respect to wildlife other than seagrass, including migratory birds, bottom-dwelling organisms (benthos), fish, marine mammals, and so on, to ordinary citizens, fishermen, environmental conservation organizations and experts.
3. Undertake a fundamental review of the Awase tidal flat landfill project from the points of view of environmental protection and socio-economic effects with a view to protecting the tidal flat ecosystem.
Sincerely,
>>>>>>>
For further information please contact:
Shinichi Hanawa (WWF-Japan Conservation Dept.)
3-1-14 Shiba Minato-ku Tokyo 105-0014 Japan
T: +81-3-3769-1013 F: +81-3-3769-1717
hanawa@wwf.or.jp
Reasons for Requesting Protection of Awase Tidal Flat and Seagrass Beds, and for Criticism of the Seagrass Transplanting Project
1． Fundamental Concepts Governing Mitigation
Article III of [Japan’s] “Law on Environmental Impact Assessment” calls on the national government, local government bodies, businesses and citizens to make efforts from their respective standpoints to avoid activities that place a strain on the environment, or to reduce that strain, or otherwise to appropriately take into consideration conservation of the natural environment.
At Awase tidal flat, transplanting of seagrass is being undertaken as a mitigation measure for landfilling seagrass beds. However, the original definition of mitigation is to 1) avoid, 2) minimize, 3) rectify, 4) reduce, or 5) compensate for impacts (1). And, in cases where development activities do take place, measures must be considered in the order given above. That is, in the environmental impact assessment, compensation measures were considered with respect to the Awase landfill project, but this amounted to choosing a fifth-rate alternative directly after it was shown that the development had to take place at Awase tidal flat. It was illogical, unscientific, and counter to the spirit of the Law on Environmental Impact Assessment to fail to consider alternatives in their proper order and jump to the conclusion that the compensation measure of transplanting seagrass was appropriate.
2. Regarding the Aims and Methods of the Seagrass Transplanting Project
According to seagrass expert Mark Fonseca, PhD. (United States National Oceanic and Atmospheric Administration), it is too much to insist that the results of a small-scale transplanting experiment will be valid for a transplanting project several hectares in extent (2). Unlike vegetation transplanting experiments conducted on land, several years of monitoring are required to judge whether the results of the transplanting experiment are a success or not. Sufficient time for monitoring the Awase seagrass replanting experiment has not yet passed, and it is far too soon at this point to judge that the project is “on the whole going well.” We are inevitably led to the conclusion that the experiment is being monitored without sufficient attention or caution. We are also forced to say that it is moreover far-fetched to tie the assumption that the transplanting experiment is going well to speeding up implementation of the landfill project.
In addition, the area where the transplanting experiment is going on is itself a healthy seagrass community, and this fact renders indistinct the meaning and aims of the transplanting experiment. The basic underlying idea of compensation is “no net loss,” that is, to essentially replace through creation by artificial means of natural ecosystems lost through development. If the transplanting project is meant to serve as mitigation, it must create new seagrass beds on a scale comparable to the seagrass beds that will be lost through landfill.
In addition, in planning this kind of experiment, it would have been essential to survey beforehand the ecological values and state of plant succession of the seagrass communities at Awase tidal flat. It would also have been essential to survey ecological factors such as species composition and percent coverage of the seagrass communities both at the site where the transplants come from as well as the destination site. A detailed transplanting plan should have been based on these kinds of surveys, but there is a lack of clarity about this point. If these surveys have not been performed, or their results not made public, it is impossible to know why this experiment is being conducted, and whether its aims and methods are meaningful in any way. It is not appropriate to base seagrass transplanting on such an insufficient experiment.
4. Present Status of the Transplanting Experiment
According to reports by researchers and non-governmental organizations that have observed the transplanting site, a great deal of dead seagrass and dead bivalve shells are seen, and it is a stretch of the imagination to say that the experiment is a success. Seagrass expert Dr. Keiko Aioi (Aoyama Gakuin University) notes that sand around seagrass roots tends to be eroded by daily tides and tidal currents, but that no measures whatever were taken to prevent erosion at the site. She also severely criticized the effort, noting that the mechanical methods used for transplanting the seagrass were identical to those in the manual for transplanting blocks of sod for soccer or baseball fields, with no consideration or analysis expended on the fact that the area is a marine environment through which large volumes of seawater flow, but rather the transplanting was progressing exactly as if it were being done on land, as if the measure was to function as a mere pretext for promoting the landfill project.
We are forced to say that this seagrass transplanting experiment and mitigation plan have been forcibly tacked on in order to expedite the landfill project. The Okinawa Development Council has stated that the seagrass replanting can be achieved using mechanical transplantation methods, but this conclusion is premature, based on insufficient monitoring surveys, which must be carried out over the medium- and long-term. There appears to be a possibility that the Okinawa Development Council has misunderstood the analysis of the experiment’s results by the Nakagusuku
Bay Harbor / Awase District Environmental Investigative and Deliberative Committee. The opinion of this Committee should be viewed as cautious.
5. The Importance of Evaluating and Protecting Awase Tidal Flat
According to “Guidelines for Conservation of Natural Habitats (Okinawa Island Version),” Awase tidal flat and the seagrass beds in the Awase area are designated as “Rank I ? area for strict conservation measures.” According to information published by the Ministry of Environment, Awase’s 138 ha of tidal flats and 112 ha of seagrass beds comprise the largest habitats of their types in Okinawa. The area has high diversity of benthos and seagrass species, with a considerable number of endangered or rare species. Awase has been included in the Ministry of Environment’s national list of 500 important wetlands. Looking at the shorebirds that visit the site, there are numerous records of Pacific Golden Plover and Gray-tailed Tattler. The site meets the criteria for designation to the Ramsar List of Internationally Important Wetlands, as well as an East Asian Shorebird Reserve Network Site. It is also potentially a habitat site for the Endangered Dugong, and could be important in future as a site to which this species could disperse.
Thus, Awase’s tidal flats and sea grass beds are valuable for their high biological diversity, as a habitat for juvenile fish and a base for supporting fisheries, as a site for migratory birds, as well as for environmental education, eco-tourism and recreation, and we believe that it will be more to the advantage of Okinawa Prefecture’s future for this area to be utilized as a natural resource in its natural state.
The present plan for utilizing the landfilled land is a relic of the 1980s, and predictions regarding the prospects for construction of hotels and offices in the resort and commercial zones and economic stimulation effects are all excessive. We are forced to conclude that the chances that these predictions will be borne out in reality are exceedingly poor.
References
(1) Masahiko Isobe, 1996. Trends in Mitigation in the United States and Issues for its Utilization in Japan. Kaigan Kougaku Ronbunshu 43:1156-1160. (in Japanese)
(2) Mark Fonseca, 2001. Seagrass conservation in the United States and Issues in Environmental Impact Mitigation and Restoration. Iyumachi No. 34:8-12 and Ibid. No. 35:7-13 (in Japanese)
(3) Keiko Aioi, 2002. Opinion Statement regarding Large-scale Mechanical Transplantation at Awase Tidal Flat (April 2002 statement submitted to the Ministry of Environment and other agencies; in Japanese)
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