Collective Views on the HKIA Master Plan 2030 by EMAHK

September 3, 2011 in EMAHK Views and Feedback

This submission is made in response to calls from the Airport Authority Hong Kong (AAHK) for feedback and opinions on the future development direction of the Hong Kong International Airport (HKIA) as outlined in the HKIA Master Plan 2030, particularly the proposal to construct a third runway to increase the airport capacity.

As a learned society dedicated to the advancement of environmental management, we are most concerned about the carrying capacity of the environment. While we welcome any measure to maintain and enhance Hong Kong’s competitiveness, we believe the society has an ineluctable duty to pursue economic development in a sustainable manner.

In compiling this response, the EMAHK has solicited views from its members and other stakeholders. The majority of our members are professionals and academics well versed in the environmental sustainability issue. On 20 August 2011, we conducted at the University of Hong Kong a public forum entitled “Master Plan 2030: Stakeholder Engagement” to gather and exchange views with stakeholders. We would like to thank the AAHK for their participation and presentation at this forum. Other participants included postgraduate students, professors, two environmental groups, namely World Wildlife Fund Hong Kong and Hong Kong Dolphin Conservation Society, and two concern groups representing Tung Chung and Ma Wan residents. A full report, which summarized the discussion and opinions raised by the speakers and participants during the forum, will be available for download from the EMAHK’s website at https//

In addition to this, a brief survey was given to our members to ascertain the present personal and professional use of the airport as well as the effectiveness of AAHK website in giving the public relevant and comprehensive information about the proposals. The survey generated interesting results including concerns about the cost of construction relative to ordinary public use. Yielded from the survey was also a mixed understanding of impacts to different stakeholders and sectors. From our standpoint, it is clear that more information is needed for a greater understanding of costs, benefits, and impacts of the proposed Options 1 and 2.

While we appreciate and support the importance of capturing the expected growth of the aviation market in the Greater Pearl River Delta region, we are also keen to see further expansion of the HKIA in a balanced direction of economic growth and sustainable development. The price tag of $136.2 billion (factoring in inflation) for the proposed third runway and its amenities will surely raise the taxpayer’s eyebrows, yet there was no holistic evaluation of economic return of the investment provided in the Master Plan. More importantly, the cost-benefit analysis (CBA) has not taken into account the external costs of the social, health, or environmental impacts. If such costs can be carefully considered and incorporated into the overall CBA, the results will be more accurate and useful to assist the public to make an informed choice.

Some attendees at the Stakeholder Engagement had grave concerns towards the lack of plans on how environmental impacts of the third runway will be mitigated. For instance, the Master Plan did not mention anything about any green measures to off-set and neutralize the increased carbon footprint because of the projected increase of air traffic movements (ATM) capacity brought by either option. No assessment was made on whether the Master Plan will preclude Hong Kong from its fair share in the international community’s effort to combat the impact of aviation emissions on climate change. Furthermore, the severe cumulative impact brought by the past and proposed projects on the Chinese White Dolphins and the fisheries around the Airport has not been fully addressed in the Master Plan. There is no information indicating on how public health impact associated with the projected air and noise pollution can be minimized and mitigated, and how the affected residents will be recompensed. We recommend that the Hong Kong SAR Government conduct a full Strategic Environmental Assessment (SEA) on the airport expansion plan. The results of the SEA shall provide more relevant information to the Public so that better informed decisions can be made while explicitly considering the balance between the environmental and developmental needs.

On behalf of the EMAHK, we strongly urge the Government to take leadership and ownership for the strategic planning and public consultation of large infrastructure projects such as the proposed expansion of HKIA. Without the missing information as described above, it is impossible for us and the Public to come up with a well-informed and justified decision on the choice between the two available options. Reaching such a foregone conclusion is mainly attributed to the incompleteness of the current consultation document. We, therefore, stress that the SEA must be carefully conducted before recommending any option for the expansion of HKIA to the Public and the Government for endorsement and funding approval. A longer and wider public consultation should be further conducted during and after the SEA. As a responsible Government and an internationally leading airport authority, it is of foremost importance that the development plan of HKIA should encapsulate a paradigm shift in focus from economic growth to sustainable development.

Summary Remarks

Public debates of AAHK’s Master Plan 2030 have been described as emotional and polarized.  This may be due to some fundamental flaws in the planning process of infrastructure projects in Hong Kong.

The statutory Environmental Impact Assessment (EIA) process is inadequate as a planning tool for infrastructure projects.

  1. EIA is often deficient since it deals with environmental impacts at the project level, when environmentally damaging irreversible decisions may have been made at the strategic level.
  2. ‘Do-the-best’ approach of mitigation design in EIA may not be effective because
  • the methods and/or data for impact prediction are not perfect (see note 1);
  •  the residual impacts may cumulate with other projects into the straw that breaks the dolphin’s back (e.g. Chinese White Dolphins near the proposed Third Runway)

Our Association calls for the Government to conduct Strategic Environmental Assessment (SEA) for incorporating environmental considerations into the policies and strategies governing future development of the Airport.  The SEA is useful and necessary because

  • information generated by the SEA should be comprehensive and detailed, allowing the public to balance the environmental, social and economic considerations and make better informed decisions;
  •  the SEA process facilitates a platform for environmental issues to be considered at the strategic level, and for the Government to take the required leadership and ownership for the planning and consultation of large infrastructure projects

We stress that the SEA must be carefully conducted and fully consulted before the preferred airport development option is endorsed and the public funding is approved by the Government.