Thought the following communication I received from the Save Fujimae
Association might be of interest to subscribers:
FUJIMAE TIDAL FLAT EIA - WHAT NEXT?
Thanks to so many of you, sixty opinion statements and letters regarding the
formidable, 1000 - page Environmental Impact Assessment for the garbage
landfill project at Fujimae Tidal Flat in Nagoya were received; of these 19
were from overseas (opinion statements from Australia, Russia, the US and a
letter from the Ramsar Convention Bureau). Thank you!
Copies of 48 statements were received by Save Fujimae Association;
altogether these accounted for over 200 pages of text. The documents from
overseas are being translated into Japanese as rapidly as possible. (Some
statements were sent to Nagoya City but copies not sent to SFA. Nagoya City
is not going to release these to SFA, so if you haven't sent SFA a copy of
your statement, please do so. Thanks!)
So, what happens now? The following is a report from Tsuji Atsuo in SFA's
excellent monthly newsletter "Daishaku-shigi" (The Curlew). (Translation by
Japan Wetland Action Network International Liaison, Maggie Suzuki)
- Let's Focus on the 'Position Statement' to be Published by the Developer
The developer (Nagoya City & the Nagoya Port Authority Management Union)
will prepare its "Position Statement" with respect to the opinion statements
received and submit them to Nagoya City. This document will be available for
public inspection for 15 days, but when it will be submitted is not yet
known. We will of course be looking to see if it honestly answers the points
raised in the opinion statements. (However, we must bear in mind that no
matter how far off the mark this statement is, in terms of administrative
procedure, no further opinion statements will be received from the public by
- Let's Call for a Public Hearing
If, within twenty days after publication of the Position Statement,
residents of the area in question call for a public hearing, or if the mayor
of Nagoya City himself judges that
such a hearing is needed, he can schedule one. We hope to call for such a
This may be difficult, as the mayor has consistently taken the part of the
- Let's Focus on the Reaction of the Decision of the Nagoya City
Environmental Impact Assessment Deliberative Council
Once a public hearing has been held, the mayor prepares an "Examination of
Environmental Impact" statement with respect to the draft EIS, and sends
this to the developer while at the same time allowing its public inspection
for 15 days. The process of drawing up this "Examination" statement includes
reference to the opinion of the "Nagoya City Environmental Impact Assessment
Deliberative Council." We'll be focusing on what kind of deliberation this
Council engages in.
[Translator's notes: "Public inspection" usually means a limited number of
copies are made available at public offices. They can usually be copied, but
are not published and generally distributed. "Deliberative Councils" are
commonplace, and are often "rubber stamp" organs. This one is made up of 23
members, all university professors.]
CONCISE SUMMARY OF OPINION STATEMENTS ON THE FUJIMAE DRAFT ENVIRONMENTAL
All opinion statements criticized the Fujimae Garbage Landfill Draft
Environmental Impact Statement ("Draft EIS") as not fulfilling the true
function of environmental impact assessment, which is supposed to properly
evaluate and judge the project before hand and determine whether its
implementation is appropriate or not in terms of necessary protection of the
environment. Most opinion statements pointed out that this Draft EIS was
merely an arbitrary device for concluding that "impacts will be small" in
order to facilitate implementation of the project, noting that it did not
consider alternatives, and that not only were there no surveys of the
ecology of the site, or of other values which would be lost, but the surveys
and evaluations which were included were often misleading, illogical or
unscientific. Many statements called for Fujimae Tidal Flats to be protected
and for the EIA to be done over, recommending objectively but pointedly that
top-class experts utilizing the latest approaches based on past experience
should undertake the revised EIA. We hope in future to compile and publish
all the opinion statements, but in the meantime here follows a concise
summary of many of the important points which were raised.
# Problems with procedure and basic assumptions
1. At a time when the national authorities are in the process of reviewing
the environmental impact assessment system, it is not appropriate to push
ahead with the very "developer-implemented, meaningless-formality"
procedures which have been the target of richly deserved and comprehensive
2. There is no recognition of Fujimae Tidal Flat as an internationally
important stopover site for migratory birds. The site should be the object
of conservation policy based on bilateral migratory bird conservation
agreements, the Ramsar Convention, and Japan's National Basic Law on
3. There is no consideration or comparison with alternatives, and no
reasonable justification for the choice of this particular site for the
development. The assessment should apply a process of logic in choosing a
4. There is no record of who performed the surveys and evaluation, therefore
no way of determining whether they possess the proper expertise, and no way
of assigning responsibility for its conclusions.
5. Environmental protection goals are vague, such as "as little as
possible." These should be expressed in unambiguous, numerical form.
6. The surveys on migratory birds and ecology should have utilized data
gathered by local NGOs and performed in cooperation with them.
7. The definition of the "affected area" is illogical, and should at least
include all of Nagoya City.
8. The procedure for public inspection are inappropriate; most citizens know
nothing about it. Copies should at least be placed in the lobbies of all
municipal ward offices, and measures implemented to encourage citizens to
inspect and comment on the Draft EIS.
9. The plan to which the Draft EIS refers was altered after the surveys were
performed to accommodate 1.5 times the volume of refuse originally planned,
so the EIA should be done over.
10. Directly after the Explanatory Meeting and when over a month remained
before the deadline for submitting opinion statements, after which public
hearing and Deliberative Council procedures still remain, the Mayor
announced that "administrative procedures will be finished within the year,"
indicating a regrettably casual attitude towards the importance of the
# Problems with content
1. There is no recognition of the history of the last thirty years during
which 95 percent of Ise Bay's tidal flats have been landfilled. The remnant
nature of Fujimae Tidal Flat alone is reason enough to protect it completely.
2. Migratory bird habitat has been largely destroyed and so the birds
concentrate on the remaining tidal flats, constituting one of the top
internationally important sites in Japan. This is ignored in the Draft EIS.
On the other hand, there has been a dramatic decline in the numbers of
shorebirds. The number of Kentish Plover in particular has declined to one
tenth of what it was ten years ago. The habitat and food sources presently
remaining are now barely able to support the birdlife.
3. The Draft EIA employs the following artificial manipulations to come up
with the shrunken figure of "1% usage rate" of the tidal flat by shorebirds:
(1) Though in one part of the document, the effect of building the retaining
wall around the landfill on bird feeding behavior is admitted, in the
overall evaluation the area which will be effected by retaining wall
construction is not considered, rather only the area which will be directly
landfilled is evaluated.
(2) The surveys of waterbird feeding patterns were conducted on four one-day
intervals only, yielding data which appears extremely unnatural compared to
observations over the course of many years and independent survey results.
Save Fujimae Association conducted surveys five times during the spring of
the same year as the Draft EIS surveys, and found preferential feeding on
Fujimae Tidal Flat at low tide by 88% of Dunlin, 96% of Bar-tailed Godwit,
58% of Curlew and Australian Curlew, 72% of Kentish Plover, 36% of
Black-bellied Plover, 56% of Great Egret, and 94% of Great Crested Grebe.
(3) Data relevant to Fujimae Tidal Flat when it is not exposed at low tide,
and considerations of species-specific behavior are missing, and instead
only a yearly average for all species is given. This is unscientific and
obviously intended to give the appearance of low shorebird habitation, which
is concentrated over a short period during migrations.
(4) To further minimize the figures, the Draft EIS emphasizes the relatively
short time span during which the flats at Fujimae are exposed at low tide by
using the smallest possible figures in a "annual exposure time span X tidal
flat area" equation in order to obscure the actual possible feeding time.
(5) Although the elevation of Fujimae tidal flats is actually 70 cm, this is
erroneously calculated as 50 cm. (On the topographical maps of the sea
floor, contour lines showing 10 cm gradations are replaced with 50 cm
gradation contour lines, clearly an artificial manipulation.)
(6) With respect to volumes of food consumption by birds, although
incredibly detailed "observation results" are provided for the content of
the food of three species, Dunlin, Rufous-necked Stint and Black-bellied
Plover, the lowest volume figure is assigned to Black-bellied Plover, which
is twice as large as the other two species. This leads us to doubt all the
4. The Draft EIA does not correctly value the productivity and water
purification functions of the tidal flat ecosystem.
(1) Basic ecological surveys were not performed with respect to Fujimae
tidal flat. A description of the flow of physical material cycles in the
tidal flat ecosystem and surveys which identify the gains and losses in
these cycles are needed.
(2) A model of "tidal flat purification volumes" is taken from the
literature and estimates given, but these conclude that the tidal flats in
the neighboring Shinkawa estuary function to purify water but that Fujimae
tidal flat does not. This result was obtained by ignoring the common sense
consideration of nutrient uptake by the primary producer benthic algae,
which perform an important function in purification of water by the tidal
(3) An extremely low figure is given for the volume of Fujimae tidal flats'
macro-benthos (large sized bottom dwelling organisms). This is because the
method used was a Smith-MacIntyre type gathering apparatus which can only
collect up to 10 cm deep into the bottom layer during high tides, meaning
that the larger crustaceans (crabs, "j
ako" and so on) in burrows 40 - 50 cm deep were not included. Surveys in
which the tidal flat surface is dug up by hand at low tide are needed.
(4) In spite of the fact that Fujimae tidal flat has been reported as the
only place in Ise Bay where "ayu" (sweetfish) are found, no importance is
attached to the expanse of brackish water on the tidal flats, which function
as habitat for juvenile fish.
5. Predictions for water pollution lead to a completely illogical
conclusion, illustrating in a symbolic way the artificiality of the Draft EIA.
(1) The area in question is located at the mouth of three rivers, and is a
brackish-water area affected by tides, but the surveys for present water
quality were performed only four times over a year without reference to the
action of tides, salt concentrations, or direction of the plumb lines. Such
careless surveys should be done over properly.
(2) In spite of citizens' groups taking pains to point out that a
consideration of bottom quality is essential in estimating the water
purification capability of the tidal flat, no such consideration is
included, indicating a weak determination to properly estimate its water
purification capability. This demonstrates insincerity with respect to one
of the most serious consequences of landfill impacts.
(3) Doubts are further raised as parameters and models used for calculating
the water pollution estimates are not identified, the figures for nutrient
loads flowing in from the rivers have been reduced without giving the basis
for doing so, etc.
(4) Although what is called for is an prediction of what effect the loss of
the tidal flats due to the landfill will have on water pollution levels, the
Draft EIS avoids making a clear statement but instead notes that "more
regular provision of sewage works and regulations on total pollution levels
will result in improvement of water quality subsequent to landfilling the
tidal flats." Though this may be relevant to impacts of the sewage works, it
has nothing to do with evaluating the impacts of the landfill project. The
conclusion drawn from this that "impacts will be small" is therefore
illogical and artificial. We can only infer that the same kind of attitude
was applied throughout the evaluation process.
6. An evaluation is needed of Fujimae tidal flat's worth as a remnant
natural ecosystem in an urban setting where people can enjoy observing
nature, where children's emotional growth can be nurtured and environmental
education take place.
(1) The Draft EIA only considers how the project site will look from far
away, and concludes that the landscape-related impact of the view from the
Wild Bird Observation Center on the far bank of the estuary will be "small,"
but we wonder if the psychological impact on bird-watchers of seeing the
feeding and resting grounds of the birds destroyed bit by bit will really be
(2) Fujimae tidal flat differs from other areas in the estuary in that its
tide pools and flats are accessible on foot, providing an opportunity to
directly observe and learn about tidal flat organisms through play. The
opportunities for bird watching throughout the year, for nature observation
outings, tidal flat study groups and children's "Tidal Flat School" have
over the last ten years been progressively developed to communicate the
wonder of the tidal flat ecosystem as widely as possible. The need for this
kind of education will, we feel, only increase in the coming years.
Landfilling the tidal flats now will ruin this opportunity.
7. From the point of view of air pollution and seepage of pollutants from
the garbage, this project should be canceled.
(1) Standards with the greatest leeway for air quality deterioration were
deliberately chosen and so the conclusion that air quality goals will be met
is misleading. The methods used for the predictions have allowed for
falsehood - in reality pollution loads will be combined with those from
nearby garbage burning plants at the Shin-nanyo facility, bringing about
predictably ill effects on health and serious impacts on the environment.
(2) With respect to seepage from the garbage, no surveys to determine the
present realities of heavy metal contamination from garbage and backfill at
garbage landfills in Tokyo Bay or other locations have been included.
Garbage landfill in marine areas should be banned, as it is in San Francisco
>From the points outlined above, it is apparent that this assessment needs
to be completely done over to include a variety of alternatives which are
compared on the basis of all factors including ecological surveys and
evaluations of social and cultural impacts. We sincerely call on the
authorities to undertake this on the basis of an improved understanding of
the importance of environmental protection.
Save Fujimae Association
Japan Wetland Action Network
2-212 Yashirodai Meito-ku Nagoya, 465 Japan
12 Florence Street
Kippa Ring, Q. 4021
Tel: +61 7 3283 4921
Fax: +61 7 3889 4272