EPA lacks guts to follow through with own dolphin impact meetings

It sounded great – the “Expert Meeting on the Impacts of Relevant West Coast Development Projects on the Humpback Dolphins and Integrated Impact Reduction Measures”. What more all-encompassing assessment could those concerned about the effects of unrelenting coastal industrial development on Taiwan’s critically endangered humpback dolphin population have asked for? Well, perhaps one that in some way reflected the intention suggested by this superb title. Now two such meetings have been held, and green groups are at a loss for positive words to describe the results.

Shortly before the first “expert meeting” on 1 June the host – Taiwan’s Environmental Protection Administration (EPA) - sent participants copies of a report that was to be discussed. Given the several dozen major development projects adjacent to or upstream of the dolphins’ habitat, it seemed somewhat inappropriate that the sole subject of the report was Taiwan Power Company’s (Taipower) Changgong Coal-Fired Power Plant, proposed for construction on the Changhua County coast. Although the expert meeting had indeed originally been proposed during an assessment meeting for the Taipower project, the impacts of one single power plant could hardly represent the diverse forms of pollution, land and water use, freshwater exploitation and underwater noise associated with all the other projects up and down the west coast. And with its all-inclusive title the EPA clearly meant to discuss the enormous collective load of all the projects on the dolphins…didn’t it?

So staff members of Wild at Heart Legal Defense Association did what they considered to be the EPA’s homework and put together a list of thirty-one projects that would likely cause major environmental changes relevant to the dolphins. This included several river damming and diversion projects, coal-fired and offshore wind power plants, petrochemical and hi-tech science parks, a steel plant and a harbour expansion project.

On 1 June, Wild distributed the list to the EPA and its expert committee. Participants from Changhua Coast Conservation Action, Changhua Environmental Protection Union, Matsu’s Fish Conservation Union, Taiwan Academy of Ecology, EAST and Green Party Taiwan all echoed Wild’s concerns that any meeting purporting to address the combined impact of all west coast projects should live up to its name.

Participating groups also challenged the quality of the Changgong power plant report, prepared by Dr. Lien-Siang Chou of National Taiwan University (NTU), as not meeting even basic scientific standards, failing to cite major relevant published reports, omitting important data, making inaccurate statements and demonstrating a bias. (Dr. Chou was hired by Taipower to carry out their study of the potential impacts of the power plant on the dolphins).

The committee concluded that Taipower would have to gather more information on the dolphins and suggest ways in which the company proposed to reduce the impact of the power plant on the population, and also that no decisions could be made based on the information that had been presented.

However, no solution was offered regarding the glaring problem of the other thirty projects.

Not one of the other projects featured in the second expert meeting on 31 July, either. Instead, a revised report by Dr. Chou focused on what the Changgong coal-fired power plant would NOT do to the dolphins – e.g. it would, apparently, not involve noisy pile-driving or obstruct their north-south movement along the coast - but failed to even mention the plant’s air pollution as a potential threat to the air-breathing mammals.

Regarding other sources of noise pollution during construction, Dr. Chou recommended adopting the 180 decibel (dB) threshold, used by the US National Marine Fisheries Service (NMFS), as the noise level at which Taipower should temporarily stop construction and start thinking up noise reduction measures.

In fact, 180 dB is the noise level at which the NMFS claims permanent physiological damage can occur in cetaceans (although scientists argue that lower noise levels can also lead to such damage). It is also widely acknowledged – also by NMFS – that noise levels far lower than this can have other important effects such as temporary hearing loss and behavioural impacts, which can be equally life-threatening to animals so dependent on acoustic signals for survival. Therefore, the adoption of a 180 dB threshold would show almost no precaution, allowing all possible levels of impact to occur - even permanent hearing loss - before noise reduction measures would be triggered.

In response to the concerns over the continued treatment of Taipower’s power plant as a proxy for all west coast cases, the chair of the meeting, Dr. Fan Kuang-Lung, a professor of oceanography at NTU, brushed these aside, and finally dismissed everyone but the expert committee for a closed door session.

The committee’s conclusions were that 1) west coast developers should act in accordance with Taiwan’s Wildlife Conservation Act (which says that humpback dolphins are a Level One protected species and, hence, affords them the highest level of protection from human activities); 2) the dolphins could be impacted by habitat destruction, pollution (including noise pollution), reduced sources of food and fisheries interactions, but that the extent of these impacts was not yet known; and 3) careful assessment of the potential for west coast development projects to cause these impacts is recommended.

The disappointment (apart from the fact that freshwater exploitation was omitted from this version of the now two-year-old list of major threats to the population) is that these conclusions only confirm what has been said repeatedly since at least as far back as the second international workshop on Taiwan’s humpback dolphins in Changhua City in 2007, although this is largely a symptom of the lack of detailed, accurate information provided to committee members - what more could they have said? Also, although this was by no means unexpected, the EPA unfortunately seems no closer than before to addressing the combined, synergistic impacts of the myriad sources of anthropogenic disturbance along the west coast.

One wonders whether the title of the meeting was an attempt by the EPA to establish a set of unspecific or irrelevant statements that could be applied arbitrarily to all projects in order to shuttle them through the EIA process, or the brainchild of a sensible, well-meaning junior official, who might then have been reprimanded for thinking out of the box. Either way, the EPA appears bent on denying the only logical interpretation of the title of its own meeting.

The hint of a silver lining glimmers, albeit very modestly, around the fact that the dolphins’ legal status has now been acknowledged by an expert committee appointed by the EPA. However, whether and how this will be reflected in action over the following months of project impact assessments will depend very much, as always, on the work of representatives from green groups attending and monitoring the EPA’s meetings.

Meeting with the military

From Wild at Heart Legal Defense Association

On 2 June, representatives from Wild at Heart, Changhua Environmental Protection Union and Matsu’s Fish Conservation Union met with officials from the Ministry of National Defense to begin discussing ways to reduce the risk of impacts of military activities on Taiwan’s Critically Endangered humpback dolphins and other marine mammals.

Live-fire exercise at Dachia River estuary on 17 June 2009

At the meeting, chaired by Legislator Tien Chiu-chin, the groups emphasized that, while their concerns had been heightened by the direct bombardment of humpback dolphin habitat from the shore near the Dachia River estuary in May and June, the potential impacts of other activities, including military sonar, on marine mammals also need to be addressed as soon as possible.

Mid-frequency sonar has been shown to have caused fatal mass strandings of four species of whale in the Bahamas in 2000, and possibly in other locations including the Canary Islands, Greece and Hawaii. Mass cetacean strandings have also occurred in Taiwan, including incidents in 2004 and 2005 that coincided with large-scale naval exercises in the region.

Wild at Heart proposed that Taiwan’s military design and implement a standard operating procedure (SOP) to protect marine mammals, as exists in various forms in countries such as Italy, France, Australia, the US and the UK.

MND representatives explained ways in which the military could improve protective measures during exercises next year, such as by moving the target several kilometers further from the shore. However, no response was given regarding sonar or other sources of noise and other disturbance.

The conservation groups and the MND agreed to continue discussions.

Ministry of National Defense responds on bombardment of dolphin habitat

In response to the letter on 16 June 2009 from Wild at Heart expressing concern over the bombardment by Taiwan’s military of critically endangered humpback dolphin habitat off the coast of central Taiwan the Ministry of National Defense has notified Wild that it has asked a number of departments within the MND, including the command headquarters of the army, navy and airforce to review the materials concerning the welfare of dolphins and the livelihoods of fishers and respond to the Department of Resources MND by 30 June 2009.

Photo: Eastern Taiwan Strait (=western Taiwan) humpback dolphin

In the meantime Wild has arranged to meet with representatives of the MND to discuss the matter of impact mitigation and explore possibilities of introducing best practices and alternatives to these exercises.

Also see:

Taiwan military fires directly into critically endangered humpback dolphin habitat 17 June

Military Exercise at Daan River Mouth 4 June

Concerns over boat-based Pink Dolphin watching

It has come to the attention of the Matsu's Fish Conservation Union (MFCU) that the Taiwan Cetacean Society would appear to be advocating boat-based dolphin watching of the critically endangered Eastern Taiwan Strait Humpback Dolphins. Both local and international cetacean experts at the Second [2007] International Workshop on Conservation and Research Needs of the Eastern Taiwan Straight Population of Indo-Pacific humpback Dolphins advised that boat-based dolphin watching of the Taiwan Pink Dolphins wasn't appropriate given their extremely threatened state and only land-based dolphin watching should be permitted and encouraged. The MFCU shares these views and actively promotes land-based dolphin watching of these critically endangered dolphins to help raise awareness of the plight of these unique dolphins. We strongly urge the Taiwan Cetacean Society to reconsider and the Taiwan authorities to act on the advice of cetacean experts and ensure that boat-loads of dolphin watchers aren't permitted near these dolphins poised on a knife edge between survival and extinction.

Taiwan military fires directly into critically endangered humpback dolphin habitat

Kyodo News reported today:

“Taiwan's military fired grenades and mortar shells into a key habitat for endangered dolphins during live-fire exercises Wednesday, an environmental protection group said.

A dwindling population of Chinese white dolphins [humpback dolphins] was at risk from howitzers in the Da-an River Estuary on Taiwan's west coast, a major habitat for the dolphins, the Taipei-based Wild at Heart Legal Defense Association said.

''The military is not showing any regard for the welfare of this critically endangered group of dolphins,'' said Christina Macfarquhar, a researcher at Wild at Heart....(Click here for the full article)

[Other than the fact that the military was firing in that area, equally disturbing was the military’s response to questions from Kyodo...]

“...Asked for comment, military media liaison officer Col. Ben Wang confirmed the exercises, saying shells had been fired into the water.

But he said he was unaware of concerns about the dolphins.

''Taiwan has Chinese white dolphins?'' he said.

''This isn't the first time we've conducted these exercises -- these are regular maneuvers,'' he added.

Macfarquhar said the military had participated in Cabinet-level meetings on protecting the dolphins, ''so they should be aware of this issue.''

''The fact that they're firing shells right into the habitat shows how much attention they've paid to it,'' she added.

Kyodo

*****

Note from Wild:

In fact, the National Council for Sustainable Development (under the Executive branch of the government) has now held two interagency meetings on “Action to Protect Taiwan’s Humpback Dolphin Population” (on 29 August 2008 and 26 February 2009) and representatives from the Ministry of National Defense attended both of them and made statements suggesting that military units were being required to reduce the impact of live firing exercises on the dolphins. But judging by today’s display this does not include avoiding firing right into their habitat.

The exercises, which were scheduled for 8.00 am to 10.30 am this morning and 2.00 pm to 4.30 pm this afternoon, were to be carried out between the Daan River estuary and just south of the Dachia River estuary (see map and weapon details in the official notice (Chinese)). Both of these estuaries are located within the dolphins’ narrow, restricted coastal habitat (see map).

Similar live firing exercises in May caused great concern amongst fishermen worried about the impacts of in these areas on coastal and estuarine ecology and on their livelihoods – estuaries are one of the most productive types of ecosystem in the world.

After receiving information about the activities yesterday, Wild at Heart Legal Defense Association faxed an urgent letter of concern to the MND, calling attention to risks to the dolphins and to fisheries. This morning, after firing had already started, the MND called to say that it did not accept faxes and to send a paper copy. The exercises continued as planned (we will post a video soon).

Wild and the other members of Matsu's Fish Conservation Union will be working with the Ministry of National Defense and the National Council for Sustainable Development to try to prevent further direct military attacks upon the dolphins.

Open Letter to Dr. Jane Goodall at 2009 International Forum on Sustainable Development

The Formosa Plastics Plant at Mailiao, Yunlin County, is typical of the heavy industry that characterises the west coast, home of the critically endangered Taiwan Humpback Dolphins.

Today is the opening day of the 2009 International Forum on Sustainable Development being held in Taipei. Amongst the foreign attendees is the world-renowned conservationist and primatologist Dr. Jane Goodall, the United Nations Ambassador for Peace. Pan Han-shen, secretary-general of Green Party Taiwan has sent an open letter to Dr. Goodall concerning the plight of the critically endangered Taiwan Humpback Dolphins. The open letter has been published in today's Taipei Times.

Also making the papers today was news that yesterday the Environmental Protection Administration's (EPA) Environmental Impact Assessment (EIA)Committee decided that Kuokuang Petrochemical Technology Co's plan to build an industrial park on reclaimed land in Changhua County needs to undergo a more thorough second-stage environmental impact assessment (EIA). See today's Taipei times for the story: Petrochemical project needs second-stage EIA.

Our colleagues at Wild at Heart Legal Defense Association posted a great piece on the 2009 International Forum on Sustainable Development titled Sustainability? The Art of Hypocrisy Reaches New Heights.

Taiwan Humpback Dolphins in the waters off Taichung county.

Military Exercise at Daan River Mouth

A 155mm howitzer crew prepares to fire their gun out to sea in a live-fire exercise in Taiwan's Matsu Islands.


It has come to our attention that Taiwan's Air Force and Army held a live-fire military exercise in early May at the mouth of the Daan River with targets being well within 3km from shore (some as close as about 1 km from shore). The Daan River mouth is a location where the IUCN Red-listed critically endangered Taiwan Humpback Dolphins have been seen and recorded on quite a few occasions. It is very disappointing to learn that the military did this without any consideration for the Taiwan Humpback Dolphins especially since they had undertaken in an earlier meeting to take into account the critically endangered population of Humpback Dolphins when conducting exercises along the west coast.

Missiles were fired at targets from helicopters and possibly from other sources. According to locals, the exercise was planned to last for ten days but after local fishermen protested, it was reduced to three days and then finally to a single day. Even a single day of blasting the known habitat of the critically endangered Taiwan Humpback Dolphins has got to be seen as grossly irresponsible and dangerous.

The main stimulus for this exercise was to burn off excess money and weapons nearing their expiry date. The military could have reduced their impact on dolphins considerably by just moving the exercises approximately 10km out to sea or only north to Hsinchu where artillery exercises often fire into waters where the critically endangered dolphins have not been seen or recorded.


Also see:
Taiwan military fires directly into critically endangered humpback dolphin habitat