To whomsoever it may concern,

I am writing as Director of the conservation NGO Birds Korea (Republic of Korea) [1], to express our organisation’s concern over the anticipated massive environmental impacts to be caused by the proposed Incheon Tidal Power Station (“The Project”). As an organisation working for sustainable development through the conservation of birds and their habitats, we believe that the Project’s proposal and aims are seriously flawed. 

We believe that the Project’s process up to now has not been sufficiently inclusive (we were for example unaware of any earlier consultations, and believe that many local stakeholder organisations were also largely or completely excluded from discussions). We believe that although the Project aim is to create more energy with fewer greenhouse gas emissions, the degradation of large areas of vegetated and open tidal-flats will lead to the loss of natural carbon sequestration and to the increased release of CO2 and methane caused when natural tidal-flats become degraded. A 2011 study found that coastal wetland reclamation typically leads to an additional release into the atmosphere of 2,000 tonnes of CO2 per Km2 per year [2].  Moreover, we believe that the Project also runs counter to proposals discussed at Cancun in December 2010 to rewet wetlands as a way of reducing greenhouse gas emissions [3]. 

We also believe that the Project application fails to address properly issues of loss and degradation of tidal-flat and the resultant threats to biodiversity (see e.g. page 38 of the application). Of major concern is that the Project will cause declines in several globally-threatened species of waterbird. The area to be impounded has been recognised as “internationally important” (as defined by the Ramsar Convention) since at least the 1980s [4]. The area supports internationally important concentrations of >10 species of waterbird [5]. These include the globally Endangered Black-faced Spoonbill Platalea minor, the globally Vulnerable Chinese Egret Egretta eulophotes, the globally Vulnerable Saunders’s Gull Chroicocephalus saundersi and the globally Vulnerable Far Eastern Curlew Numenius madagascariensis. All of these species are ecologically dependent on intertidal wetland. The project area also regularly supports globally Endangered Red-crowned Crane Grus japonensis, Globally Endangered Nordmann’s Greenshank Tringa guttifer and Globally Vulnerable Great Knot Calidris tenuirostris.  The presence of all of these species should be well-known to Project proponents, as the area has been regularly surveyed by government as well as non-government researchers; and a substantial part of the project site was earlier designated as a protected area – especially for Black-faced Spoonbills.

We believe that the proposed Tidal Power Plant will increase disturbance throughout the Project area and in adjacent areas, and will lead to changes in natural ecology. Most importantly, it will greatly reduce the area of exposed tidal-flat available for these bird species to feed in at low tide, and also time available for them to feed. This will result in reduced fitness and over the long-term, declines in their population.

It is of great concern that the Project proposal contains no names of any species believed to be potentially threatened by the project; no scientific journals or papers to support claims relating to “alternative habitat” to be created; and no reference to existing protected areas which will be affected.

Following extensive literature review and discussions with leading experts over many years, Birds Korea is unaware of any evidence that waterbird species which presently depend on the existing intertidal wetland can be supported at present population levels in adjacent areas. Instead, all relevant scientific literature (e.g. [6,7,8,9]) indicates that a reduction in area and quality of habitat will lead to population declines.

We are also mindful that our nation, through being a contracting party to international conservation conventions, agrees to use wetlands wisely and to conserve threatened species. Conversion of intertidal wetland to a reservoir for the Incheon Tidal Power Station will change the ecological character of c. 20,000ha of Ramsar-defined internationally important intertidal wetland. Under the Ramsar Strategic Plan 2009-2015, the ROK has already formally committed the nation to “manage wisely” (i.e. to conserve) all internationally important wetlands within its territory, whether these wetlands are Ramsar sites or not [10].  Through the Millennium Development Goals, the ROK also agrees to reduce the rate of biodiversity loss, yet the Incheon Tidal Power Station will lead to a continuing loss of biodiversity of species ecologically dependent on intertidal wetlands. Under the Convention on Biological Diversity, the ROK has agreed to reduce the rate of loss of natural habitats and to improve the conservation status of threatened species [11]. The proposed Incheon Tidal Power Station will however lead to the loss of 15% of all remaining natural intertidal wetland in the ROK, and it will destroy the natural habitat of several already globally-threatened bird species.

We therefore believe that the proposed Tidal Power Plant is “unsustainable development”, and that its validation under the CDM will encourage destruction of this and potentially of other internationally important intertidal wetlands (including Garolim Bay, Cheonsu Bay and Saemangeum). In turn, this is predicted to lead to further declines in biodiversity and the loss of services that such natural intertidal wetlands provide, including carbon sequestration.

Sincerely,

Nial Moores
Director Birds Korea
IUCN Species Survival Commission Member (Threatened Waterbirds Group).


References

1. Websites at Birds Korea: at www.birdskorea.or.kr ; www.birdskorea.org
2. Crooks, S., Herr, D., Tamelander, J. Laffoley, D. & J. Vandever. 2011. Mitigating Climate 
    Change through Restoration and Management of Coastal Wetlands and Near-shore Marine 
    Ecosystems. Challenges and Opportunities. Environment Department Papers. Paper Number 
    121. (in English). At:  www.worldbank.org/environment/publications
3. Feldman, S. 2010. Out of Cancun Climate Talks, a Breakthrough for Preserving Wetlands 
    Globally. InsideClimate News, December 21st 2010:  http://insideclimatenews.org/news/20101221/out-cancun-climate-talks-breakthrough-preserving-wetlands-globally
4. Research organized by Professor Won Pyong-Oh of Kyung-hee University and 
     published internationally in:
    Long, A., Poole, C., Eldridge, M., Won Pyong-Oh & Lee Ki-Sup.  1988. A Survey of Coastal 
    wetlands and Shorebirds in South Korea, Spring 1988. Asian Wetland Bureau, Kuala 
    Lumpur.
5. Moores, N. 1999. Korean Wetlands Alliance National NGO Wetlands Report: Ramsar 1999.  
      142 pages.  Published by Yullinmaul, Seoul.
6. Burton N., M. Rehfisch & N. Clark. 2003. The Effect of the Cardiff Bay Barrage on 
      Waterbird Populations, Final Report. British Trust for Ornithology Research Report 343.
7.  Burton, N., Rehfisch, M., Clark, N. & S. Dodd. 2006. Impacts of sudden winter habitat loss 
       on the body condition and survival of redshank Tringa totanus. Journal of Applied Ecology 
       43: 464-473.
8.  Moores, N., Rogers, D., Kim R-H, Hassel, C., Gosbell, K., Kim S-A & Park M-N. 2008. 
       The 2006-2008 Saemangeum Shorebird Monitoring Program Report. Birds Korea 
        publication.
9.   Moores, N. 2011. The Distribution, Abundance and Conservation of Avian Biodiversity of 
        Yellow Sea Habitats in the Republic of Korea. Unpublished doctoral thesis, University of 
        Newcastle, Australia (in English).
10. Ramsar Strategic Plan 2009-2015.     
      http://www.ramsar.org/pdf/key_strat_plan_2009_e.pdf
11. Convention on Biological Diversity, Aichi Biodiversity Targets (2020), at:
       http://www.cbd.int/sp/targets/

Incheon tidal power station will be destroyed the ecosystem of Yellow sea.
The reduction of CO2 that badly damages is meaninglessness.
So I oppose Incheon Tidal Power Station CDM Project.

Endangered species are living and breeding on the tidalflat of Incheon.
Especially tidalflat that is on the brink of disappear is Black faced spoonbill's habitat.
If tidalflat disappeared, no longer the birds.
I want Ecoeye Co.to cancel this project.

When Incheon tidal power station is constructed, 85% of tidalflat will be disappear.
Most of the tidalflat of the Yellow sea in Korea was reclaim already.
I think Korea government should find another way to sustainable energy policy.
The tidal power station can destroy the ecosystem and lives of fishermen and stakeholders.
I against building the Incheon tidal power staion.

I have uploaded two files. my opinion is the same as them

 Incheon tidal power station CDM project is just a plan not constructed. And local government and local fishermen, all of Korean NGOs don't agree, so I think it will be stop to build soon or later. 
The ides of construction of the station was stupid  and the proposal to CDM project is nonsense because the Yellow sea is one of the high biodiversity ecosystem of large marine ecoregion in the world. 
I'm agree with the SAVE international(Yekang Ko and Derek K. Schubert) and Bird Korea 

I EHI of Korea Institute for Environmental Studies has been active in the private sector. I am definitely opposed to Incheon tidal power projects. 

Incheon tidal power projects are eco-destructive business.  Threaten the livelihoods of local fishermen and is destroying the habitat of numerous bird mobility. Damage the habitat of the endangered spoon-bill, and many coastal tidal flats are expected to undermine. Power plants due to a maximum of 7.65 ㎢ Seongmo Island tidal flats of Inchon reduced. An estimated 70 to 80 percent near the fishermen losing operation based on a serious level of the marine ecosystem is destroyed. The majority of South Korea Incheon Tidal private environmental groups oppose development projects. Incheon also have the academic and religious communities are opposed to the tidal power project. 

Mobility of birds and fishermen, and coastal wetland ecosystems, and so did not go to enough for a review. 

- Discreet enough to request a review. 

- Eco-Horizon Institute

I EHI of Korea Institute for Environmental Studies has been active in the private sector. I am definitely opposed to Incheon tidal power projects. 
Incheon tidal power projects are eco-destructive business. 
Threaten the livelihoods of local fishermen and is destroying the habitat of numerous bird mobility. Damage the habitat of the endangered spoon-bill, and many coastal tidal flats are expected to undermine. Power plants due to a maximum of 7.65 ㎢ Seongmo Island tidal flats of Inchon reduced. An estimated 70 to 80 percent near the fishermen losing operation based on a serious level of the marine ecosystem is destroyed. The majority of South Korea Incheon Tidal private environmental groups oppose development projects. Incheon also have the academic and religious communities are opposed to the tidal power project. Mobility of birds and fishermen, and coastal wetland ecosystems, and so did not go to enough for a review. 

- Discreet enough to request a review. 

- Eco-Horizon Institute

Incheon Tidal Power Station Project 
should not be registered as CDM Project.

< Incheon Federation For Environment Movement >



1.	INCHEON TIDAL POWER STATION PROJECT RESULTS IN DESTRUCTION OF ENVIRONMENT.
By this project, the large dam which is 18km will be built, leading marine ecosystem to devastate and biological diversity to vanish. In addition to environmental damage which includes mud flat decrease, coastal fishing will be affected severely. 

2.	IT IS THE MOST BEAUTIFUL WETLAND OF KOREA WHERE THEY ARE DESTRUCTING. 
The construction spot is the only wholly preserved mud flat in South Korea. Ganghwado coast has high preservation value thus local residents, environmental organizations and Korea Environment Corporation make effort together to designate as ‘national mud flat park’.

3.	WETLAND PROTECTED AREAS AND NATURAL MONUMENT ZONES ARE PLACED IN THE CONSTRUCTION SPOT.
Incheon Tidal Power Station Project withdraws some parts of wetland protected areas and natural monument zones. The construction spot includes Ganghwa mud flat, blackfaced spoonbill’s breeding place which are natural monuments. Furthermore, this is the place where the government is carrying forward as Ramsar wetland.

4.	THE LOCAL RESIDENTS AND FISHERMAN ARE STRONGLY OPPOSING TO THE PROJECT. 
The construction spot is a very crucial place for coastal fishery. This project will devastate coastal fisheries, greatly decreasing the haul. That’s why 17 fisher villages are strongly protesting to the project. Fishermen whose livelihoods are under threat due to Incheon Tidal Power Station Project had been holding several assemblies. 

5.	THE PROJECT WILL INFLUENCE ONE OF THE WORLD’S ENDANGERED BIRDS, BLACKFACED SPOONBILL.
Black faced spoonbill is an endangered bird which lists in the red list of IUCN. The only place where it use as habitat is the Incheon coast. This project will affect blackfaced spoonbill’s inhabitation and reproduction. Moreover, rare birds and water birds will also get fatal influences. 
In addition,
&#61656;	Mud flat will be decreased and devastated.
&#61656;	Seawater’s effectiveness will decrease, aggravating water quality.
&#61656;	Fish’s routes will be blocked and it will be damaged because of turbines.
&#61656;	Marine ecosystem will be affected by a sudden increase of jellyfish.
&#61656;	Fishery will be desolated, biodiversity decreases, catch of fish decreases. 
&#61656;	Marine life’s inhabitation and reproduction will be effected.  
Thus, many oceanographers in Korea are expressing worries and counterviews. We recognize that CDM consider environmental benefit importantly to reduce green-house gases. 
However, Incheon Tidal Power Station Project only destroys marine environment. The project is never beneficial to the environment. 

Incheon Tidal Power Station is not CDM project. It can change and destroy the ecosystem of the intertidal zone. It can menace the survival of the endangered species such as Black-faced Spoonbills, Chinese Egrets, Saunders's Gulls, and Far-eastern Curlews. It has a plan to build the bank of 20km length and it can reduce a lot the function of Gas exchange and purification by the intertidal mudflat. 

Dear Sirs and Madams,

I have review the Incheon Tidal Power Station CDM Project application, and I do not believe it contains adequate information to assess it’s environmental effects.

For example, regarding the project’s effects on tidal-flat water flows, Table D.3 Expected impact and counter measures against for the project activity, only indicates:
Change in tide

    High tide within the sea water reservoir made by
    the project activity: Decrease of 10~40cm

    High tide [sic] within the reservoir: Increase of
    170~200cm

For such a large-scale project, costing trillions of Korean won to construct, an example of some of the minimal information needed to understand the project’s effects on tidal flats would include:

(1) A map showing areas to be
(1.1) permanently inundated at low tide,
(1.2) permanently dry at high tide,
(1.3) permanently filled due to the installation of the seawall
(2) A tabulation of the above areas and the current biological habitat in those areas
(3) Graphs showing the changes in tidal flows accompanied by tables showing how the diurnal length of inundation will be change within the remaining inter-tidal areas.

As a Civil Engineer who observed some of the rapid filling and draining of tidal flats around the Yellow Sea, in both Korea and China, from 2006 to 2009, I humbly suggest that the project proponents consider the following suggestions in order to better protect the public health, safety, and welfare in Korea.

(1) Study the effects of tidal power via seawall impoundments on biodiversity at ShiHwa Lake, Korea. Located just south of the proposed Incheon Tidal Power Station, the ShiHwa Lake tidal power plant, which started full operations this year, may provide a suitable location for studying whether the mitigation claims in the Incheon Tidal Power Station CDM Project application are valid. Before constructing another large and expensive seawall near Incheon, the ShiHwa seawall and tidal-power system should be carefully studied.

(2) Using information gained from studying ShiHwa, evaluate if tidal power can be implemented at the SaeManGeum seawall, North Jeolla Province, Korea, without damaging the remaining tidal flats landward of the SaeManGeum seawall. Since 2006 at least approximately 250 square kilometers of former tidal flats – drained by the SaeManGeum seawall – remain unused. Rather than (or at least before) building a new seawall near Incheon, tidal power could be retrofitted at SaeManGeum for:

(2.1) Much lower additional taxpayer/ratepayer cost (since the seawall is already built).

(2.2) Probably provide faster return on the investment in the SaeManGeum seawall than current real-estate development plans (Korea Times, The, 2010.04.27 19:29, "SaeManGeum to Draw Foreign Investors" by Kim Tae-gyu, http://www.koreatimes.co.kr/www/news/biz/2010/04/123_64950.html).

(2.3) Allow the US$10 billion Korean taxpayer (and possibly some of the US$10 billion private) future investment called for in current SaeManGeum development plans to be applied to other projects in North Jeolla Province, closer to existing population centers.

(2.4) Much less future damage to ecosystems and biodiversity. At SaeManGeum major damage to tidal flats has already been done, and increasing flows through the seawall for tidal power may start to reduce past damage, if it is done with care to avoid damage to the important remaining tidal flats landward of the SaeManGeum seawall.

Thanks for your consideration.

–
James D. Hadley, P.E.
Member ACS, AIChE, ASCE
Fact Fancy, LLC
Columbus, Ohio, USA

Dear Sirs

Incheon Tidal Power Station CDM Project

We are writing to express our very serious concerns about the application for Certified Emission Reduction (CER) credits under the Clean Development Mechanism (CDM) for the Incheon Tidal Power Station Project in the Republic of Korea.

The Royal Society for the Protection of Birds (RSPB) is the UK partner in BirdLife International and has over one million members. Conservation of the intertidal habitats of the Yellow Sea is a priority for us due to our leading role in work to prevent the extinction of the critically endangered Spoon-billed Sandpiper which is entirely dependent on the Yellow Sea as a staging area during its annual migration and also because of our work, on behalf of BirdLife International, to ensure conservation of other globally threatened migratory waterbird species which also depend on the intertidal habitats of the Yellow Sea, including through the UN Convention on Migratory Species and IUCN.

We fully support the comments made by BirdLife International about the Incheon Tidal Power Station Project. This project could have a devastating impact on to the environment and biodiversity of the Yellow Sea, and in particular on the waterbirds that migrate along the East Asian-Australasian Flyway.

The tidal flats that would be lost as a result of the project are an important stop-over site for shorebirds and other waterbirds on migration from their breeding grounds in North-East Asia and Alaska to their wintering grounds in South-East Asia and Australasia. Many of these waterbirds are highly specialised, meaning that intertidal wetlands are the only place that they can find the food that they need to sustain their migration. Some of the bird species affected are globally threatened, including Black-faced Spoonbill (Endangered on the IUCN Red List), Red-crowned Crane (Endangered), Chinese Egret (Vulnerable), Far Eastern Curlew (Vulnerable), Great Knot (Vulnerable) and Saunders’s Gull (Vulnerable).

In addition to their value for biodiversity, tidal flats are very carbon rich habitats. Hence loss or alteration of the tidal flats as a result of the Incheon project will result in decreased carbon sequestration and the release of vast amounts of stored carbon to the atmosphere as CO2, bringing into question the carbon reduction benefits claimed for the project in the PDD.

However, despite the potential extent and severity of these impacts, they have not been adequately analysed in the environmental assessment procedures carried out for the project to date and are not mentioned at all in the Project Design Document.

In light of these potential impacts we do not believe that it is appropriate for the project to be recognised under the CDM. The RSPB would be happy to discuss our concerns with you in more detail if this would be helpful.

Yours sincerely,

Dr Tim Stowe
Director of International Operations, RSPB

cc
Dr Marco Lambertini, CEO, BirdLife International
SGS United Kingdom Ltd

Contact details:

RSPB
The Lodge, Sandy, Bedfordshire, SG19 2DL, UK
Tel: +44 1767 680551, Fax: +44 1767 683211
Website: www.rspb.org.uk