Dr. Nial Moores, National Director, Birds Korea.
(Below is a modestly extended English-language version of an article on the proposed Busan New Airport on Gadeok Do which was translated by Park Meena, Birds Korea National Coordinator, for publication in Korean by Pressian on August 4th 2024. The article is accessible together with dozens of expert articles and news accounts on this proposed airport at:
https://www.pressian.com/pages/search?sort=1&search=%EA%B0%80%EB%8D%95%EB%8F%84
A much more detailed report on flaws in the EIA and our bird surveys can also be found here).
“I was not born in Korea. Instead, I first moved to Japan from the UK, and then on to Korea 25 years ago, to conduct research on birds and their habitats . I chose Busan as my new home city, in large part because of the beautiful landscapes and good air quality; and because of the tremendous biodiversity, especially in and around the Nakdong Estuary where there was a mix of bird species (e.g., migrant Spoon-billed Sandpipers 넓적부리도요 and White-naped Cranes 재두루미 and wintering Relict Gulls 고대갈매기 and Steller’s Sea Eagles 참수리) found together nowhere else in the world.
Like so many places, Busan has changed greatly over the past two decades. A huge new port has been built; new roads and bridges have been constructed, including across the Nakdong Estuary; and village after village has been replaced by concrete forests of apartment blocks. Accordingly, the few data on birds that are available show major declines in many species. And now, starting in December 2024, the plan is to bulldoze one of Gadeokdo’s mountains into the Nakdong Estuary and then, within five years, to build an airport on top of the rubble. As announced in 2022, Busan is also proposing the construction of a “Second Coastal Ring Road”. As proposed, this would be another 75km or so of new road, much of it over the sea, to link the airport more directly to tourist areas in the east of the city and all the way to Ulsan.
As someone who loves this city, I cannot understand the rationale for all of this additional infrastructure, or the sense of urgency. The construction of the past two decades has already diminished the city’s character and its biodiversity; and research shows that it has also failed to stop either the city’s decline in population or the super-aging of the population that remains, with 23% of residents now aged 65 or older. Decades of infrastructural development and the promise of the new Busan International Airport on Gadeokdo also failed to persuade the rest of the world that Busan should host the 2030 EXPO, in spite of all the money spent on PR. Instead, Riyadh in Saudi Arabia won that right. Why? One reason is that Saudi Arabia highlighted the significance of the year 2030 for the environment and for sustainability. As explained on their official website (https://riyadhexpo2030.sa/), 2030 will be the year in which, “Global efforts are centered around the UN’s Agenda 2030 and its Sustainable Development Goals (SDG)”. The SDG, agreed to by all member states of the United Nations, provide a target-based framework for sustainability built on three foundational pillars: the environment, society and the economy. Economies and societies need a healthy environment if they are to survive and thrive.
Busan City’s 2030 EXPO bid was focused instead on the decades old message of the need for more infrastructural development, including the new airport, and the power of technology. The city’s natural environment was presented as background scenery, and not as foundational to the city’s future. Busan’s approach might have been more honest than some other candidate cities, but it was a misreading of the seriousness with which many nations now take climate change, declines in biodiversity, and the importance of both to people’s well-being. Busan was seen to be falling behind cities that showed even a minimum commitment to the SDG and long-term sustainability.
And now, the planning process for Gadeokdo, with its many similarities to the flawed planning process for new airports on Jeju and at Saemangeum and in half a dozen other important areas for biodiversity, means that it will become yet another example of Korea’s outdated development model. This is a development model that has already severely damaged both Korea’s environment and also the nation’s environmental image overseas, just like the reclamation of the Saemangeum tidal flats and the Four Rivers project before it.
First, Busan new airport’s proposed location in the southern quarter of Gadeokdo was previously rejected multiple times by domestic and international experts because of the likely economic, social and environmental costs. Nonetheless, this same site was again selected, largely to support Busan’s now-failed bid to host the 2030 EXPO. Because this area contains the homes of hundreds of people and is also nationally important for biodiversity and cultural heritage, a special law was passed to help overcome legal challenges and to facilitate construction. Then, and only then, an Environmental Impact Assessment (or EIA) was conducted.
The purpose of every well-designed EIA is to identify likely impacts of a proposed development early on in the planning process, so that decision-makers can make informed decisions, including cancelling projects without wasting huge amounts of money. Generally, the larger and potentially more impactful the development, the more thorough the research and analysis needs to be. The EIA process for the Gadeokdo airport, consisting of research, publication and expert review, took less than one year. This meant that the final report could be published in August 2023, three months before the final vote on the EXPO 2030 host city was taken.
How does this kind of rushed and apparently unstoppable process ensure a healthy and pleasant environment, as long called for in the National Constitution? And how does it help the nation to compete globally in the growing “green market revolution”, with potentially trillions of dollars at stake?
The Gadeokdo EIA claims to be a Strategic EIA, which in other developed nations means that the airport development is put into a national policy framework, and a detailed assessment of alternatives is provided, including whether or not a new airport is even necessary. A Strategic EIA might also be expected to assess the cumulative impacts of related infrastructure, such as new roads. But by my reading, the Gadeokdo EIA report does not appear to contain any meaningful consideration of policies or alternatives or refer to the Second Coastal Ring Road. Instead, most of the EIA report is focused on the very same area which had been pre-selected for the airport years earlier, and on areas up to 13km out from it, in accordance with guidance provided by the International Civilian Aviation Organisation (ICAO). ICAO is a special UN Agency that plays a central role in ensuring safety and sustainability of airports and aircraft around the world, in ways that are consistent with UN environmental protection policies and practices.
My review of the Gadeokdo EIA was largely focused on sections which were relevant to birds. Airport EIAs typically focus on two main bird-related issues. The first is the likely impact of airport construction and operation on birds and their populations. The second is the risk of bird strike on aircraft. The Gadeokdo EIA report fails in both respects.
In addition to increasing greenhouse gas emissions, construction of the airport will result in the loss and degradation of forest and marine habitats that support nationally important biodiversity, and a small number of globally threatened species. Operation of the airport will cause additional negative impacts. Earlier this year, a proposed new international airport in Lisbon, Portugal was cancelled. This is because research showed that increased noise levels caused by low-flying aircraft during take-off and approach for landing would be harmful to migratory waterbirds. The Gadeokdo airport will be built within 7km of the Nakdong Estuary, much of which is protected under national law; and within about 10km of the Geoje coast. Both, according to Ministry of Environment data, are internationally important for waterbirds as defined by Ramsar Convention criteria. Waterbirds in both areas will be affected by increased noise caused by aircraft. But although the Gadeokdo EIA is more than 2,000 pages long, it does not consider the impacts of increased noise levels on any waterbird at all.
Even more important, perhaps, is the failure of the Gadeokdo EIA to respond properly to specific guidance provided by ICAO as it relates to bird strike. Bird strike is a serious and growing problem for aircraft throughout the world, resulting in the death of birds, damage to aircraft and sometimes, human fatalities. To reduce the risk and severity of bird strike, ICAO mandates that all international airports must have a Wildlife Hazard Management Plan.
According to ICAO, every Wildlife Hazard Management Plan must be based on research on wildlife, including birds, conducted throughout the year. Research is also needed on bird behaviour as it relates to aircraft. This includes an assessment of flock size and height of flight especially in the vicinity of the runway and in areas used by aircraft on approach and take-off. This is because the vast majority of bird strike incidents have been reported when aircraft are flying below about 610m, the height many commercial aircraft fly below when they are 13km or less from the runway.
The research on birds for the Gadeokdo EIA was conducted on only 62 dates between November 2022 and July 2023. The research did not even cover a whole year. Moreover, very little survey work was conducted in the vicinity of the proposed runway, or in areas lying below aircraft approach and take-off. In addition to surveys, specialized radars are also often employed in other developed nations as part of the EIA process to track bird movements. No radar studies were used for the Gadeokdo EIA. Instead, a total of about 50 birds were captured, and locators were put on them in order to track their movements. None of these birds, however, were trapped in the immediate vicinity of the proposed airport or in the flight path used during take-off or approach for landing. Instead, many were trapped about 50km away. The results from this kind of research therefore have little to no value in assessing the bird strike risk for aircraft using the proposed Gadeokdo airport. Inclusion in the EIA report of these data therefore seems to be more misleading than helpful.
Lacking funding from either university or government, our own research on Gadeokdo has also been limited. We conducted counts on eleven dates and counted a combined total of almost 11,000 birds overflying a small part of the proposed runway area in Daehang Village, at a rate of 2-3 birds per minute. The vast majority of these birds were flying at a height where bird strike seems likely, including a large number of raptors.
The large numbers of raptors and other migratory birds we counted during our surveys is because of the physical geography of Gadeokdo and adjacent regions. Most bird species do not like to migrate over the sea, and Gadeokdo is situated adjacent to the shortest sea-crossing between the Korean Peninsula and Japan. Gadeokdo therefore sits on a main migration route, used by many species. The island is also shaped like an upside triangle, so that birds migrating south become concentrated in the triangle’s southern quarter. In addition, raptors worldwide are known to follow hill ridges during migration, and to form large flocks near the coast. This is because many raptor species are heavy and large, and they need to wait for thermals and rising air currents, as are often found around hill peaks, to help them gain height before attempting to fly over the sea. The high hill peaks either side of the proposed runway area in Daehang Village provide the last opportunity for raptors and other soaring birds to gain height before departing southward over the sea, and their first opportunity to gain height after they arrive from Japan.
The safety risk to aircraft posed by bird strike is defined by ICAO as the probability of a strike multiplied by the severity of damage caused. Generally, heavier birds and greater flock size increases the probability of damaging an aircraft and impacting its flight performance. The presence of flocks of raptors flying low over Gadeokdo, sometimes for an hour at a time, suggests that there will be a substantial risk of severe damage to aircraft.
In order to reduce the risk of bird strike, ICAO-approved Wildlife Hazard Management Plans can call for the removal of attractants, local habitat destruction, bird-scarers and in the worst case, the killing of birds that live near the runway. However, there does not appear to be any established method for preventing raptors and other birds from following long migration routes that are fixed by regional geography as is the case for Gadeokdo. Instead, it even seems possible that airport construction might increase the bird strike risk. This is because reflected heat from the runway tarmac could become an attractant to soaring raptors as they migrate back and forth between Japan and the Korean Peninsula.
The lack of understanding of bird migration shown during the site selection process and presented in the EIA report means that the current risk of bird strike, and the severity of that bird strike, is still being greatly underestimated. Why was this serious issue not raised properly during the formal expert review of the EIA?
It is clear that most people in Busan and nationwide, including law-makers, remain unaware of many of the environmental and social problems associated with the proposed new airport, even now. Bad science presented in this EIA report (just like the bad science in the EIA reports for the Jeju and Saemangeum new airports), is very hard to separate out from good science, unless you are a specialist. It is therefore a reason for celebration that the airport is currently being openly challenged in court. This court case should finally provide an opportunity to ask and answer important questions and for Busan city to find a more sustainable path to 2030 and beyond.
Busan is my home. And Busan already has the natural and cultural assets to stand proud on the global stage.
To become a global leader, however, the city and the nation now need to reject the old development model, adopt international best practice in planning, and fully embrace the SDG, before it is too late.”
