To: Mark Barter <>, (Mike Weston)
From: Julian Bielewicz <>
Date: Wed, 11 Dec 1996 07:23:53 +1000

It is no secret that no matter how badly we think we have it in the "West,"
the Japanese Government can still go one better (or should that be one
worse?).  The Japan Wetlands Action Network  once again seeks our help with
one of their continuing struggles.

Maggie Suzuki (International Liasion) sent me the following communique.  I
think you'll find it disturbing reading.  It may egg you into action to help


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 beforehand 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
development site.

4.      There is no record of who performed the surveys and evaluation,
therefore no way of determining         whether they possess the proper 
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 
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 
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 
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 
tenth of what it was ten years ago. The         habitat and food sources 
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 

                (1) Though in one part of the document, the effect of building 
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 
one-day intervals                       only, yielding data which appears 
extremely unnatural
compared to observations over the               course of many years and 
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 
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 
unscientific and obviously intended to give the appearance                      
of low
shorebird habitation, which is concentrated over a short period during

                (4) To further minimize the figures, the Draft EIS emphasizes 
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, 
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 
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 
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
flat ecosystem.

                (3) An extremely low figure is given for the volume of Fujimae 
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, "jako" 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 
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 
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

Address: Dept. of Math. Meijo University
 1-501 Shiogamaguchi Tenpaku Nagoya, 468 JAPAN

Phone:   81-52-832-1151 Ext 5054
Fax:     81-52-832-1169

The Japanese Government does apparently respond to international pressure.
This could be an opportunity for us to squeeze a little in support of
Japan's dwinling wetlands.


Julian Bielewicz
12 Florence Street
Kippa Ring, Q. 4021

Tel: +61 7 3283 4921
Fax: +61 7 3889 4272

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