向城市規劃委員會揭示最新海事安全問題信息，呼籲不可通過改劃三跑土地用途

（圖片來源：立場新聞）

我於2月1日去信城市規劃委員會，揭示最新海事安全問題信息，指出地政總署於1月14日才寄出有關此專題的顧問報告給我，以致我無法在1月11日和12日的城規會聽證會上，就此作出詳盡和準確的討論，又指出顧問報告內容含有錯誤和揭示出懸而未決的海事安全問題，其中更涉及跨境交涉未見政府協調的重大問題。
我強烈呼籲城規會，在顧問未能解釋和糾正錯誤之前，在海上安全仍有未解的懸念時，萬萬不可通過改劃三跑土地用途。給城規會電郵信函全文附錄如下。

URGENT URGENT Re: Draft Chek Lap Kok Outline Zoning Plan No. S/I-CLK/13

Dear Sir,
This message serves to inform TPB that I have received from Lands Department two Marine Traffic Impact Assessment (MTIA) Reports and that the new information revealed that TPB has not be fully apprised of the serious marine and aviation safety problems and that the assessment of the acceptability of additional risk of marine accidents by the consultant was grossly wrong.  Under such circumstances, TPB must not make any decision on the Draft CLK OZP now.

I attended TPB meetings on 11 and 12 January 2016.  On 12 January, on slides No. 10 and 11 of my powerpoint presentation, I expressed concern about the impact of the third runway and the associated reclamation on maritime safety as well as the impact of marine transport on aviation safety.

At that time, I commented that: (a) no information was available from the Marine Traffic Impact Assessment Report (b) the growth of ocean-going vessels was under-estimated (c) no information was available on the impact of tall ships on aviation safety
I specifically mentioned that no MTIA reports were available at that time.  I also reminded TPB that until it has sufficient information on the subject and until the questions about safety issues are cleared, no decision should be made.

Two MTIA reports were dispatched to me by Lands Department with a letter dated 14 January.  I was required to reply by 28 January.  I eventually sent my reply re-affirming my formal objection under the Foreshore and Sea-bed (Reclamation) Ordinance on 26 January.  The reply with detailed explanation of my grounds is attached. (註1)

The point of critical importance is that I discovered a gross mistake made by the consultant in computing and assessing the societal risk of additional marine accidents arising from the third runway.  By following the correct procedures, the re-computed values of frequencies of accidents resulting in N or more fatalities (N = 1, 2, 3 and 10) all fall within the "UNACCEPTABLE" zone in the relevant diagram.

The contents of the MTIA Final Assessment Report (March 2015) also confirm that the number of ocean-going vessels has been under-estimated and that the impact of tall ships (including oil drilling platforms and derricks with high airdraft) on aviation safety remains an open issue with no solution, especially with regard to tall ships "cutting corners" in Mainland waters off the north-west corner of the marine restricted area and with regard to tall ships in Lantau Island Anchorage No. 2 (again in Mainland waters) off the western end of the third runway.  

In the light of this new and substantive information, the TPB must not allow the proposed revision of the CLK OZP now.
To help the layman understand the complex issues, I have written a blog article (which was also published in Ming Pao on 31 January).  It is also attached. (註2)

You are requested to urgently communicate this message as well as the attachments to the chairmen and members of TPB, to apprise them of this latest information (which has been kept away from me until after my attendance at TPB meetings). 
 [中譯：請你緊急把這封信和附件傳送給城規會主席和委員，讓他們知道這方面的最新信息]

I strongly recommend that TPB require the proponent of OZP revision to supply the two MTIA reports to TPB immediately, and to allow me an opportunity to explain the gross mistake which the consultant has made as well as the other risks which deserve close examination. 
 [中譯：我強烈呼籲城規會要求項目倡議人立即向城規會提供該兩份海上交通影響評估報告，給我機會向城規會解釋顧問的重大錯誤，以及其他必須仔細研究的風險。]

To proceed to make a decision on OZP revision without addressing this safety issue in full would push Hong Kong people into a less safe regime regarding marine and air transport.  It would also not be due process nor good governance.
[中譯：沒有深入處理安全問題而作出修訂規劃大網圖決定，會把香港推到航海和航空交通不安全的境地，有違盡責審查原則，也不是良好管治所為。]

"Safety" is one key value which TPB is required to uphold according to the Town Planning Ordinance.  Please do ensure that it is not overlooked or pushed aside owing to "economic" consideration.
[中譯：根據城市規劃條例，「安全」是城市規劃委員會必須恪守的核心價值，懇請保證安全不會因為所謂「經濟考慮」而被忽略或擱置一旁。] 

Please kindly acknowledge receipt of this message and confirm in due course the communication of this message to chairman and members of TPB.

Regards, Lam Chiu Ying​ TPB/S/I-CLK/13-C138 and R399

註1 見：《草雲居》 2016年1月30日   「向地政總署遞交重申反對三跑填海的信函（1月26）」

註2 見：《草雲居》 2016年1月31日 「讀了顧問報告令人更擔心 - 海空安全懸念未解，三跑此刻不可填海」