Open Letter to IUCN #4: Independent Scientists Find Major Flaws & Omissions in ROK Government Environmental Impact Assessment
The following statement is the 4th open letter mailed to the leadership and/or members of the International Union for Conservation of Nature. It was originally posted here.
TO: IUCN Leadership, All Participants, International Union for Conservation of Nature (IUCN), 2012 World Conservation Congress, Jeju Island
FROM: Jeju Emergency Action Committee
IN PRIOR OPEN LETTERS TO IUCN, we referred to the unsatisfactory, Environmental Impact Assessment (EIA) prepared by the Korean government to allow building a giant naval base to home-port Korean and United States missile-carrying warships. The South Korean Navy conducted the EIA, concluding that its construction would have little impact on the surrounding environment, including on the ecosystem of Tiger Island, a UNESCO Biosphere Reserve. While the Navy’s 2,000-plus-page document appeared rigorous, external scientific reviewers found it excluded key impacts to endangered coral and wildlife species and ignored other significant factors.
As we also reported, over the last month, an independent team of researchers, including IUCN affiliated members, were doing a separate study to assess the accuracy and biases of the government report and to indicate its own findings and recommendations. The researchers felt they needed to operate secretly, even when diving along the reefs, because the government has been deporting people when it suspects they might shed light on the terrible impacts of the military base, or on the police brutalities visited upon the local indigenous villagers of Gangjeong. (More than two dozen researchers and scientists from several countries have already been deported by the government, including one member of our own team, Dr. Imok Cha, the highly renowned physician from the United States.)
Today we are pleased to provide links to two of the independent assessments and one communiqué from the researchers:
“An Independent Environmental Impact Assessment (EIA) of Coral Communities Surrounding the Intended Site of the Gangjeong Naval Base—Including Analysis of Previous Research and Findings.” This report is by Greenpeace-East Asia, Green Korea United, and SaveJejuNow, based partly on the observations of a series of deep-diving units, was prepared by Simon Ellis, Dr. Katherine Muzik, , Sanghoon Yun, Boram Bae, Jinsoo Kim, and Dr. Imok Cha. http://savejejunow.org/eia-of-coral-communities-gangjeong-naval-base/
“Endangered Species Relocation Assessment—Civilian-Military Complex Port Development, Jeju Island, South Korea.” This report was prepared by Endangered Species International (San Francisco.) The individual authors of this report have asked not to be identified for the moment, as they continue work in Korea, and fear government sanctions. http://savejejunow.org/endangered-species-relocation-jeju-island/
“Sacred and Spectacular Soft Corals of Gangjeong” general observations by Dr. Katherine Muzik http://savejejunow.org/sacred-spectacular-soft-corals-gangjeong/
Protection of the People, Nature, Culture and Heritage of Gangjeong Village
Because of reports such as these, and others, an emergency motion (Motion 181: Protection of the People, Nature, Culture and Heritage of Gangjeong Village) has now been introduced for an IUCN membership vote this week.
The Motion asks the Korean government to:
(a) Take appropriate measures to prevent adverse environmental and socio-cultural consequences associated with the construction of the Civilian-Military Complex Port Project;
(b) invite an independent body, to prepare a fully transparent scientific, cultural, and legal
assessment of the biodiversity and cultural heritage of the area and make it available to the public; and
(c) Restore damaged areas.
SELECTED INDEPENDENT FINDINGS
Below is an abbreviated summary of a few of our independent findings:
* Navy EIA Dismissed Designations to Protect Jeju Soft Corals: The government EIA made no mention of the great uniqueness, or spectacular attributes of the Jeju soft coral habitat being endangered by the Navy base construction. The base construction is underway in the midst of a large globally unique contiguous Jeju Soft Coral Community—-9264 hectares—-which is, presumably, already protected as Natural Monument 442, by the Cultural Heritage Administration of Korea. The site is only 1.3km away from Tiger Islet, designated as the core area of a UNESCO Biosphere Reserves in 2002.
What makes the Jeju Soft Coral Community possible is its adjacency to a nutritionally rich, tropical current flowing through northern waters, and its remarkable unique combination of ancient Andesite larva rock sea bottom, and abundant vertical walls, down to depths of 60 m. The Korean Navy report neglected to cite a seminal paper by the leading authority on Jeju soft coral, Dr. Jun Im Song. In her exhaustive three-year research of the entire Jeju Soft Coral Habitat, Dr. Song found 82 species of coral, including 42 indigenous species, 24 endangered species (out of 38 total protected species known in Korea.) (See full list in NOTE below.)
Dr. Song reports “Coral habitat plays a variety of important roles, not only in terms of ecological stability and structure, but also as an important resource for tourism.” In Korea, the great majority of such corals are found in the southern coast of Jeju. At a geo-biologic level, this region offers this rare coral community an ideal potential for continuous propagation. However its location within such a unique region, creates vulnerabilities for ecological stress.
Dr. Katherine Muzik, a member of the current team researching the Navy EIA, says this: “I can state unequivocally, based on my personal observations and a review of pertinent scientific literature, that Jeju’s octocoral assemblages are unique, spectacular, and worthy of special protection. They form the largest and most spectacular temperate Octocoral forests known on Earth.”
* Ignored Endangered Species: The government EIA omitted two endangered species and one endemic species: the Boreal Digging Frog (Kaloula borealis), an IUCN Red List species; the Red Foot Crab (Sesarma intermedium); and also the rare, endemic Jeju Shrimp (Neocaridina denticulata keunbaei) found only on Jeju and nowhere else in the world. It was only after the Navy EIA was challenged by Korean NGOs, that the government indicated it would relocate the above threatened species. But the relocation process has been a failure. According to the independent researchers, no adult frogs were ever moved to safety. They are now being crushed under heavy construction machinery. Some tadpoles were moved, but the agency that was supposed to monitor them did not. When one of our team inquired about this, we were told, “Monitoring was not possible last year.” To date, no report is available.
Some shrimps were also moved to a new site, but it caused dangerous overpopulation in that location; and some crabs were moved to a new habitat, but that habitat is now being destroyed as well. So, all three species are seriously threatened, and there is no meaningful “monitoring” of the situation.
* Baseless Claims About Sea-Bottom Habitat: The government’s EIA asserted that the sea-bottom in areas of construction were completely sandy, and that therefore there are no coral colonies within the main construction area. Yet, the government conducted no research of the ocean floor in this area! These claims were only assumptions! The government then placed the area off-limits to outside diver/investigators. However, independent researchers have since pointed out that since Dendronephthya suesoni is found only 500m from the construction site, at the Gangjeong Lighthouse, then it is therefore highly likely that it and other endangered corals also inhabit the construction zone. Furthermore, local dive-masters, who’ve dived there as many as 7,000 times, strongly argue that the government’s assertion is wrong, and that significant coral colonies do exist, attached to rocky areas that can be found in many places within the main construction site.
Meanwhile, our independent team’s divers were able to dive along the edges of the construction site, and found 34% coral coverage at a depth of 12 meters. This finding flies in the face of another fallacious statement in the Navy EIA — that there are no significantly large coral colonies living in the vicinity of the base site. Our divers also found “dense groups of the spectacular endangered Dendronephthya putteri corals.”
* Omitted Three CITES-Protected Coral Species: Three other species of endangered corals were also found by our divers, omitted from the Navy EIA, despite that they are protected by the Convention on the International Trade in Endangered Species (CITES): Montipora spp, Alveopora spp., Dendrophyllia spp.
* Storm Threats: Typhoon Bolaven, hit the Gangjeong construction site on August 28, causing tremendous damage to the seven giant floating caissons used in construction of the sea wall and weighing almost 9,000 tons apiece. During the storm, all seven caissons were heavily damaged and two of them broke free and sank. The sunken caissons will have damaged coral and other benthic populations in and around the base. Now the government is in a quandary about how to clean up the mess. It has claimed it will use a “floating technique” to remove the sunken caissons, but how that can be achieved was not explained. Base construction workers were overheard discussing plans to blow them up, under the water! This would cause catastrophic damage to the entire underwater ecology. In any case, there is every indication that inadequate precautions have been taken by the base construction team to ensure the protection of the environment during the construction phase of the project, especially in this location known for being typhoon-prone. If there were no other reason to stop all construction, this would be sufficient. Functional ports should be built in protected harbors — not exposed to the open seas, as is the Gangjeong coast. Imagine what global disaster might unfold should a typhoon hit one of the nuclear submarines slated to be ported here.
* Omits Impacts of Maritime Traffic: The Navy EIA does not mention the effects of constant maritime traffic. It is expected that there will be trauma and mortality to ecologically important coral populations from the constant passing of large ships. A nearby unique and spectacular soft coral garden, measuring 73.800 sq meters (15 acres) is located only 14 m below the surface and many naval vessels have a draft of 10 m or more. Neither does the Navy EIA mention the routes through the shipping channel. The south eastern sea wall of the base is only 250 m from the UNESCO Biosphere Reserve buffer zone. The Navy EIA omitted the fact that cruise ships and aircraft carriers can measure 350 m in length, which is longer than the distance between the base and the buffer zone.
* Sediments/Heavy Metals: The Navy EIA indicated that there are concentrations of heavy metals in sediments around the Gangjeong Navy base. (This, despite that two key heavy metals, mercury and arsenic were not measured.) However, it confirmed that the heavy metal content of the sediment is high enough to be highly toxic to marine life, released into the water column through dredging or disturbance. The Navy EIA includes only a vague mention of long-term effects of sedimentation. Sedimentation is known to coat corals, increase stress, reduce growth and survival of corals and eventually kills them. Persistent siltation also coats rocks, prohibiting new colonies from taking hold and regenerating coral populations. Fine silt left from the construction may remain in the area for years and get stirred up into the water column whenever there is rough seas or large waves.
Long lasting sedimentation will eventually kill any corals that have not already been killed by the direct trauma of dredging, fill deposit, or wall construction. Thousands of coral colonies are at risk. These dangers are obviously ultimately unavoidable, and are sufficient to warrant cancellation of this base.
* Excludes Mitigative Measures Against Oil Spill Dangers: The Navy EIA states that measures should be taken to protect against fuel spills, but does not say what measures can be taken. Fuel, oil and other organic hydrocarbons can have serious effects on marine benthic organisms, even in small quantities. Corals are especially vulnerable to dispersed oils, especially lighter fuels such as gasoline, diesel and light crude. Other fluids associated with engine maintenance and function, such as antifreezes, lubricants and detergents, are also harmful. It is highly likely that once the base is operational there will be a constant release of small amounts of fuel into the environment. This contamination will have long-term negative effects on surrounding coral populations already stressed by other factors such as sedimentation, reduced flow and pollutants such as TBT and other heavy metals. Should there be a major spill or oil from the base site, the ramifications would be even worse, possibly leading to mass mortality in coral populations. The Navy EIA neglects to sufficiently address any of these problems, let alone mitigation.
* Toxic Paints, etc.: Navy EIA recommends discouraging Navy ships from using anti-fouling paint Tri-butyl Tin (TBT). TBT is banned on small ships. But Navy ships and large ships are currently exempt from this ban. A large ship such as a navy destroyer can add 200g of TBT into the environment over a 24 hr period. TBT is very stable and can remain in sediment unaffected for 7-30 years. TBT is highly toxic to corals, oysters, clams, and abalones. Coral reproduction and recruitment will be severely restricted by these chemicals as they leach into the water, accumulate and remain active. The Navy report does not suggest how to ensure that such a ban could be enforced, as ships will be arriving from all over the world.
* Ineffective Mitigation: The Navy recommends completely inadequate and ineffective mitigation measures. For example, it recommends “silt protectors” all around the construction zone. (Errant silt protectors from the base were already seen floating off Tiger Islet during moderately heavy seas on Aug. 23rd. Later, after the August 28 typhoon, every silt protector at the construction site had been ripped to shreds.) The Navy also recommends using “fall pipes” to lower rocks and other materials into the water, which have never proven adequate, and which workers don’t use anyway; workers have been seen recklessly dumping rocks and fill materials into the water.
* Inadequate Addressing of Water Flow Problem: Because soft corals cannot survive without clean, constantly flowing water, the water flow rate will be severely obstructed by the construction of a large navy base. The Navy EIA suggests that the water flow rate will not be significantly changed in areas 500 meters from the base. But once the base is complete, there will very likely be a significant drop in current flow rates around the East and West sites surveyed by our independent EIA team. This will mean fewer nutrients to corals and will cause sediment to drop down quickly, smothering corals and other bottom dwellers. The Navy suggests an “Ocean Water-Way Activation system” to regulate ocean water flow to protect corals. But there is no empirical evidence that such a process would ever be helpful to maintain coral populations east and west of the base. It is guesswork.
* Omits Fact that Large Ships Will Travel Through Core of UNESCO Biosphere Reserve: The Navy EIA omits crucial information regarding paths that large ships must take as they enter the port. And yet, this may be the most potentially destructive issue in the entire project. Neither is there is any mention of where ships will gather to wait while seeking entry to the port.
According to the Navy’s “simulation study” studying wind effects in the port area (February 2012), it was first determined that the sea route that would best avoid impacting the UNESCO Biosphere Reserve buffer zone, (Route #1) would be “too dangerous” for the ship, and might lead to devastating impacts on the sea walls. This is because entry would require a steep turning angle of more than 70 degrees. A safer sea route should be no more than a 30 degree turning angle.
Both proposed entry routes to the naval base present serious problems. Route #1, the originally route, turns out to be dangerous for ships, as it requires a 70 degree turn with risks of crashing. The Navy now contemplates route #2, which would send ships directly over and through rare spectacular soft coral reefs, with high risk for their destruction. Both are unacceptable.
Only last week it was announced by the Korean Department of Defense that the original route (#1) needed to be abandoned, and that a new route (#2) was preferred, especially in bad weather. However, in the new route, ships will invariably have to navigate through the UNESCO Biosphere core zone (See Map) http://savejejunow.org/reports-human-rights-environmental-destruction-naval-base/
The core zone of the UNESCO Biosphere Reserve contains a spectacular world of soft coral colonies, including one famous massive Coral Garden, measuring 73,800 square meters (15 acres). Alarmingly, this Coral Garden lives only 14m below the surface. But expected naval vessels may have a draft of up to 17m, bringing the prospect of a constant prop-wash from passage of large ships. This will surely bring trauma and death to amazing, ecologically-important coral populations. So, the conclusion can only be that while sea route #1 is unsafe for ships, sea route #2 will destroy an ecological paradise.
Better to move the base somewhere else.
These are only a few of the many serious problems of the Navy EIA that disqualify it as an exhaustive meaningful study that can help mitigate all the problems that a Navy base will and already is bringing to Jeju. These are all aside from the dire effects upon an indigenous community which has lived sustainably in this area for thousands of years, in close economic and spiritual relationship to the local environment.
It will be a great step forward if the IUCN community votes to support the upcoming
Motion 181: Protection of the People, Nature, Culture and Heritage of Gangjeong Village.
Thank you so much for your attention.
EMERGENCY COMMITTEE TO SAVE JEJU ISLAND
Global Fund for Women; Korea Policy Institute
Imok Cha, MD
Physician; Save Jeju Now
Inter’l Forum on Globalization; Foundation for Deep Ecology
Kauai Alliance for Peace and Security
NOTE: Protected coral species found in Jeju Soft Coral Habitat
Song. 2009. Jeju Coast Soft Coral Habitat, Coral Distribution Study, Consolidated Report.
1. Dendronephthya suensoni¸ 1
2. Dendronephthya mollis¸ 1
3. Dendronephthya putteri¸ 1
4. Dendronephthya alba¸ 1
5. Dendronephthya castanea¸ 1
6. Euplexaura crassa¸ 1
7. Plexauroides complexa¸ 1
8. Verrucella stellata¸ 1
9. Montipora trabeculata¸ 4
10. Pasammocora profundacella¸ 4
11. Alveopora japonica¸ 4
12. Caryophyllia (C.) japonica¸ 4
13. Dendronephthya arbuscular¸ 4
14. Dendronephthya b. boschmai¸ 4
15. Tubastraea coccinea¸ 1,4
16. Cirripathes anguina, 4
17. Antipathes densa, 4
18. Antipathes dubia, 4
19. Antipathes grandiflora, 4
20. Myriopathes bifaria, 4
21. Myriopathes japonjca, 1,2,4
22. Myriopathes lata, 3,4
23. Myriopathes stechowi, 4
24. Plumapathes pennacea, 4
Numbers on the right indicate Conservation Status:
1) Endangered Species Level II, The Ministry of Environment of Korea
2) Natural Monument No. 456, The Cultural Heritage Administration of Korea
3) Natural Monument No. 457, The Cultural Heritage Administration of Korea
4) CITES II