Ten Fallacies of The Three-Runway System

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Francis Neoton Cheung calls out 10 reasons why the government should hit the pause button on the Three-Runway System. He’s not saying never, but something more complex.


(中文原文: 張量童:「三跑的邏輯謬誤」)

Mr. Wilson Fung Wing-yip from the Hong Kong Airport Authority (AAHK), several others and I spoke on May 23 at the “Beyond the Three-Runway System” forum. Mr. Fung is one of the ex-Administrative Officers whom I admire the most. He is eloquent and sharp-witted. He knows his stuff. However, he is also the will-o’-the-wisp that lures his audience into the Trap of Logical Fallacy.

“The total passenger throughput of the major airports atop the Pearl River Delta estuary will reach 300 million by 2030.”

I have always been in full support of expanding the Hong Kong International Airport (HKIA) in sync with the socio-economic growth of the city.  Where I disagree is with the idea that the “Three-Runway System” (the 3RS) is the best option. When Mr. Fung became Executive Director (Corporate Development) of the AAHK back in 2011, his most important mission was to hard-sell the 3RS proposal drawn up by his predecessors. The almighty AAHK, despite having the experience of formulating three HKIA Master Plans, opted for the 3RS, the least efficient and cost effective of the plans. This might be due to the fact that the 3RS could be implemented within the shortest time frame. This is the same logic that animated the initial introduction of the Chek Lap Kok Replacement Airport project back in 1989.

Interests, vested and vocal

Airlines, logistic companies, and other air transport-related industries and unions (except the flight attendants unions) would support whatever expansion project for the airport was proposed as they are not the ones to foot the bill. In general, the business sector, construction sector, professional consulting sector, subcontractors and suppliers also backed the proposal in the hope of getting a share of the financial benefits the 3RS might bring.

Those antagonists are seen by some as busybodies who challenge the Government’s authority for the sake of doing so or as radical environmentalists who push their ideals at the cost of hindering social development. Many also think that the issue is too complicated for them to comment on. Worse still, there is an obvious lack of thorough analysis by political parties and lawmakers. In these people’s minds, the 3RS seems unalterable, a ‘take it or leave it’ proposition. Under such circumstances, the AAHK is close to claiming victory in what should have been a scientific and rational skirmish of policymaking.

10 Ways to fall

“Dichotomic language and hard-selling should come to an end.”

Fallacy #1: The planning process is well justified.
First, since the Chek Lap Kok Replacement Airport started operation in 1998, the AAHK formulates an HKIA Master Plan looking 20 years ahead. Three master plans so far are updated every five years with regular review. This practice seems systematic and reliable. Truth be told, however, this is exactly what undermines the AAHK’s strategic planning and ability to grasp the best timing to implement appropriate development components in steps with demand.

The five year review builds on past reports, but the original sin of Chek Lap Kok has never been addressed, nor corrected. In the beginning, the AAHK failed to address the geographical limitations of Chek Lap Kok before the airport was built. Constrained by the mountainous terrain of Lantau Island, the two existing runways cannot operate independently from each other due to wind shear and obstacles to certain approaches. Additionally, HKIA’s airspace overlaps with some other airports in the Pearl River Delta region, which further restrains runway operation.

Second, previous master plans have never looked farther than 20 years ahead. The AAHK claims that long-term forecasts lack credibility because nobody can accurately predict what is going to happen in the future. However, the golden rule when it comes to planning strategic transport infrastructure is ‘long-term vision, one-off planning, incremental implementation, and constant review’. In other words, we should first set out a general framework, and then implement it step by step according to the needs for air transport and economic development each time. Frankly, the AAHK should come up with a planning framework that is expandable, sustainable, technically feasible and financially attainable. It might even articulate a grand proposal that is expected to support as many as four to six runways, in which lands should be reserved for future expansion, and related infrastructure planned beforehand.

Third, when formulating the five-year plans, the AAHK did not carry out any interim review examining the discrepancy between previous assumptions and the actual demand situations. Had the AAHK had done that earlier; it would not have been caught in this awkward situation. It was not until 2015 that the AAHK “suddenly” realised the actual demand in 2016 would exceed the airport’s capacity, while expansion projects remained stagnant.

Fourth, other viable proposals, such as construction of a second airport or collaboration with airports in Shenzhen and Zhuhai, were never considered seriously by the AAHK. The Executive Council never got to consider other proposals except the one and only one recommended by the AAHK.

Fifth, the AAHK did not provide an Air Traffic Impact Assessment (ATIA) report when it presented the 3RS to the Town Planning Board (TPB). The TIA is an indispensable technical document that is required whenever a development proposal is submitted to the TPB for approval. According to the AAHK’s estimation, the total passenger throughput of the major airports atop the Pearl River Delta estuary will reach 300 million by 2030. One could imagine how overcrowded our airspace will be by that time.

In the absence of an ATIA, AAHK failed to provide a Safety Risk Assessment (SRA), in accordance to International Civil Aviation Organisation (ICAO) Annex 19, on the worst scenario – during the busiest hours while anticipating bad weather conditions coupled with missed approaches and aircrafts’ mechanical failures, etc. Real Time Simulation (not only Fast Time Simulation) of aircraft movement patterns under these scenarios considering the flight paths, escape avenues and queuing loops, etc. will demonstrate if the assumed design capacity of the 3RS could be achievable or otherwise. This uncertainty will cast doubts on the operation-effectiveness and cost-effectiveness of the 3RS. Such planning and decision process and procedure are likely to be subject to challenge and judicial review when the TPB gazetted the Chek Lap Kok rezoning plan on May 8.

“Once the white elephant project has taken off, there is little LegCo monitoring can do.”

Fallacy #2: The Three-Runway System has wide support from the public
The AAHK consistently claims the 3RS has gone through public consultation and is widely supported by the public. It is true the AAHK commissioned a survey conducted by the HKU Social Science Research Centre from June to September 2011, in which 24,000 respondent questionnaires were collected. According to the poll results, 80% of respondents agreed that the plan for airport expansion should be finalised as soon as possible. However, respondents were only presented with two pre-selected options: to stick with two runways, or to build the 3RS. Two other options, ‘dual airport system’ and ‘Cross-Pearl River Delta collaboration’ simply went unmentioned. How can this survey be credible?

Fallacy #3: A mutually-beneficial air traffic management system can be achieved with the support of the Central Government
As mentioned, when the total passenger throughput of the five airports in the Pearl River Delta region amounts to 300 million, airspace constraints and risk management concerns mean all airports in the region might not be able to provide adequate aircraft handling capacity for the demand.

The interests of different airports might be balanced by technical and management measures; but if conflict does occur, we cannot be sure of the Central Government’s attitude. It might be supportive of Hong Kong today, but it is uncertain whether it will remain the same tomorrow. Unlike border checkpoints, which are managed solely by Customs, airspace is under the portfolio of the PRC State Council, where the military has a stake. The Central government welcomes Chinese cities to develop their own airport facilities according to their respective needs and advantages. The key question is, however, how is the Central government going to handle economic conflicts among cities? Overshadowed by distrust between China and Hong Kong, ‘domestic diplomacy’ might not be the once-and-for-all solution to the conflict. Why don’t we build a second airport to the  south of Lamma Island? Far away from the delta, embracing the South China Sea, where our planes can fly freely. Being further away from the PRD estuary, there will be ample space for Hong Kong’s aircrafts to climb up gently before entering the prescribed altitudes within the mainland boundary. Overlapping airspace is definitely avoidable.

Fallacy #4: Airspace limitations will not affect the capacity of the 3RS
This argument is founded on unsound presuppositions about the aircraft handling capacity of a runway system is determined solely by the mode of operation, be it independent operation, semi-independent operation, take-off only, or landing only. It is oblivious of other possible situations, such as bad weather, engine failure, missed approaches, and more. More importantly, airspace limitations would make the 3RS prone to delays and cancellations under Chinese air traffic control. In that case, it would not be able to realise its full capacity.

“80% of respondents agreed that the plan for airport expansion should be finalised as soon as possible.”

Fallacy #5: Regrouping of air routes is impossible under current air services agreements
China-Hong Kong integration is the most logical result of geoeconomics. That said, co-opetition between Pearl River Delta region and Hong Kong might carry on regardless. It was proposed that the Shenzhen International Airport (SZIA) would open more domestic routes to second-, third- or even fourth-tier mainland cities, which actually makes a great deal of sense.

Currently, Cathay Pacific (wholly owning Dragonair) and the China Air are in a state of mutual shareholding. Having the SIA take over the direct flights to second- and third-tier mainland cities is certainly a viable option. Unfortunately, the Hong Kong-Shenzhen Western Express Railway connecting HKIA-Hung Shui Kiu-Qianhai-SIA might be stalled due to high costs and low returns. However, planners should consider how we might enhance other modes of transport between HKIA and SIA by land and by sea.

Fallacy #6: Diverting passenger throughput whose destinations are second- and third-tier mainland cities to SZIA is meaningless since they only make up as little as 1.6% of HKIA’s total passenger throughput
This is true for the time being. But in the long-term, by enhancing the connecting transportation between HKIA and SZIA, the role of HKIA as a global air travel hub would be reinforced. For example, if one travels from Paris to a third-tier Chinese city like Jingdezhen, he might first arrive at HKIA, and then transfer to SZIA for Jingdezhen. More travellers would actually consider Hong Kong as the endpoint of their journey. Hong Kong would appear more appealing as a tourism destination. Moreover, under smaller traffic pressure, Hong Kong would be able to open new air routes to emerging markets and cities along ‘One Belt One Road’.

Fallacy #7: Dual airport systems generally fail
Some dual airport systems do fail, but that does not necessarily suggest that all dual airport systems are bound to fail. It depends on the site selection, connecting transport infrastructure to the central business district (CBD), and complementary services and facilities. Shanghai’s Hongqiao Airport and Pudong International Airport are relatively successful examples of dual airport systems.

Fallacy #8: The price for environmental conservation is economic development, which is a cost too high for our society.
The proposed site of the 3RS is also the habitat of Chinese white dolphins and a fishing area. In the process of building the 3RS, the government will have to maintain the dolphins’ habitat and compensate fisheries. These huge costs are not all included in the estimated costs of the 3RS. If there are other alternatives, such as building a second airport, the government would be free from these extra perpetual financial burdens.

Fallacy #9: The AAHK will be able to cover the costs of the 3RS on its own
The AAHK is in a healthy financial state right now, generating a cumulative profit of HK$35 billion for the government up to date. However, if it is to pay over HK$200 billion (probably due to inflation and cost overrun) for the 3RS , that might require the borrowing of HK$100 billion instead of the currently planned HK$50 billion, it would be a rather great impact on the AAHK’s finances. Following the high construction costs, the maintenance and service costs might undermine HKIA’s competitiveness as well. At the end, the deficit would have to be borne by the AAHK’s sole shareholder–the Hong Kong government.

Fallacy #10: Setting up monitoring committees in the LegCo and Airport Consultative Committee would be enough for holding the project accountable
This would only apply if the proposal pre-selected by the AAHK would eventually get through the statutory planning procedure, thus forcing Hongkongers to ‘pocket’ the 3RS for the time being. Once the white elephant project has taken off, there is little LegCo monitoring can do.

I must reiterate that I support the AAHK’s continual investment in expanding and enhancing the airport facilities, but that must come with operation- and cost-effectiveness, acceptable environmental impact, and planning sustainability. I call for the government to re-evaluate its plans to expand the airport, and compare different options rationally, scientifically, and objectively. There should be public discourse regarding the different aspects of the project, including the economics, the social impact, sustainability, and China-Hong Kong integration. The High Court’s decision on May 20 to approve two judicial reviews regarding the environmental impact assessment certainly has sound reasons.

Where there is danger, where there is opportunity and this is the crucial hour. It was predicted that the judicial reviews might take as long as four years, and that would offer sufficient time for redesign and re-planning. Once a consensus is reached, opposition voices would naturally disappear, and the project could be carried out more smoothly.

In response to Transport and Housing Bureau’s wishful thinking – “t is not ‘why and whether’, but ‘when and how’”. I believe plans for expanding the airport should return to the question of ‘what and where’.

Truth arises from discourse. Dichotomic language and hard-selling should come to an end. If the Three-Runway System still emerges to be the best option after completing technical assessments and having considered all other viable options, the government should provide adequate explanations and facts to convince the public.

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Francis Neoton Cheung

Francis Neoton Cheung is the convenor of Doctoral Exchange (http://doctoralexchange.hk/), a public policy research collective, and a former member of the Hong Kong Airport Consultative Committee and the Land and Building Advisory Committee.”]