(March 25, 2011) Chinese geologist and environmentalist Fan Xiao has sent a letter to high ranking Chinese officials, urging them not to destroy the rare fish conservation zone they’ve created on the Yangtze. Plans are in the works to build the Xiaonanhai dam within the conservation zone, which would be the second time the Government redrew the zone to accommodate dams. Building the dam would violate the government’s own environmental protection rules, and would put over 100 rare species of fish at risk. He calls for public hearings and an administrative review, in hopes of convincing officials to abandon the plan.

Below is an excerpted version of Fan Xiao’s open letter, translated into English by Probe International

An open letter on the need to protect the rare-fish reserve zone in the upper Yangtze River

Dear Premier Wen Jiabao of the State Council
Dear Zhang Ping, Director of the National Development and Reform Commission
Dear Zhou Shengxian, Minister of the Environmental Protection
Dear Han Changfu, Minister of the Agriculture
Dear Chen Lei, Minister of Water Resources
Dear Cai Qihua, Director of the Changjiang Water Resources Commission
Dear Bo Xilai, Secretary of the CPC Chongqing Municipality
Dear Cao Guangjing, Chairman of (Board of Directors) of the Three Gorges Corporation,

The nationally designated rare-fish conservation zone on the upper Yangtze is facing a critical situation. The boundaries are being re-drawn once again as the Xiaonanhai dam, which is situated in the reserve zone, is expected to be launched soon. A statement about the proposal was posted on the official website of the Ministry of Environmental Protection after a panel of experts last November agreed that shrinking the conservation area would not ruin the aquatic habitat.

The Yangtze River, the world’s third largest river, is traditionally referred to as China’s mother river. It plays a pivotal role in meeting the needs of sustainable development and maintaining the planet’s biodiversity and ecosystem. There are 119 rare fish species in the Yangtze but their living environment is deteriorating and their survival space has become smaller and smaller.

The population of rare and unique fish species has been in decline since the 1980s, primarily due to the construction of the Gezhouba Dam on the main channel of Yangtze in 1988. The number of Chinese sturgeon, for example, has sharply declined because the Gezhouba Dam blocked the species’ migratory path. The Three Gorges project, just upstream of Gezhouba, has made the situation worse. Based on the study by experts at the Institute of Hydrobiology of the Chinese Academy of Sciences, the Three Gorges project alone would reduce the habitat for about two-fifth’s of the Yanztze’s unique and rare fish species by about 25% in the upper reaches of the Yangtze.

Ma Yi, vice director of the Yangtze Fishery Resources Administrative Committee expressed his concerns about fish in the Yangtze. He reported that the fish fry population for the four most popular cultivated fish species has dropped at an alarming rate since the Three Gorges reservoir was filled in 2003. Also, official data indicates a 90 per cent drop in the fish fry population between 2004 and 2006, compared to the population before 2003.

Mr. Ma further pointed out that while there are benefits to building hydro dams on the Yangtze, the dams have had tremendous negative impacts on aquatic life: destroying aquatic habitat, blocking fish migratory routes, and flooding or simply destroying fish breeding grounds, all of which has led to the decline of various species, a huge decline in fish populations, and even unusual changes in the genetic makeup of different species. More importantly, the effect of this entire destructive process may be irreversible: species that cannot adapt to the altered aquatic environment will go extinct, causing a gradual loss of biological diversity in the Yangtze valley.

To mitigate the impact of the Three Gorges dam on rare fish in the upper Yangtze, local governments built the Luzhou Rare Fish Reserve Zone and Yibin Rare Fish Reserve Zone in 1996. One year later, the government of Sichuan Province approved a plan to combine the two zones and re-name it the Provincial Yangtze Hejiang-Leibo Rare Fish Conservation Zone. In April of 2000, the State Council promoted it to a National Yangtze Rare Fish Conservation Zone. In the same year, however, the Three Gorges Corporation, builder of the Three Gorges project, was planning to build a string of dams on the Jinsha River (upstream of Three Gorges)– with two of the four dams, Xiangjiaba and Xiluodu, located in the conservation zone.

To push the two giant hydropower dams ahead, the Three Gorges Corporation asked the State Council to redraw the boundaries of the conservation area to exclude the heart of the zone – the stretch of the river between the future Xiluodu and Xiangjiaba dams. The State Council agreed to the request in April 2005, re-designating the protected fish zone to an area downstream of Xiangjiaba – clearing the way for the dams to be built. The new reserve zone covers the section of the Yangtze from Yibin downstream to Chongqing, along with the lower reaches of the Min River, and a small section of the Chishui River where it joins the Yangtze.

After re-drawing the Conservation Zone boundary, the State Environmental Protection Administration pledged not to allow more hydro dams to be built within the new reserve zone.

So far the reserve, stretching from Yibin in Sichuan Province to Chongqing, the upper limit of the Three Gorges reservoir, is the only natural river section and last haven for fish species in general and rare fish in particular in the main channel of the Yangtze, including white sturgeon (bai xun), Yangtze (or Dabry’s) sturgeon (dashi xun) and rouge fish (yanzhi yu) and so forth.

Recently, the government of Chongqing committed to building the Xiaonanhai dam on the Yangtze, which will put the redefined national reserve zone at risk again. This would remove a 95.8-kilometre stretch of the reserve zone – about 27% of the total length of the reserve zone on the upper Yangtze (353.16km).

Located in the river section between Yibin and Chongqing, the dam site of the Xiaonanhai is far from favourable. There, the river is wide and the height of the river is small for power generation. Unlike the Three Gorges and other big hydro stations on the Jinsha River, where the dams can be built as high as one hundred, two hundred and even three hundred metres, the Xiaonanhai’s design height is only 50 meters. Even though the dam is not very high, the inundation losses will be huge, because the would-be-flooded area is flat, dominated by low hills and basins.

It has been reported that building the Xiaonanhai would affect four districts in Chongqing: Dadukou, Jiulongpo, Banan and Jiangjin. About 70,000 mu (46.7 square kilometres) of arable land would be flooded, and key projects affected such as the Baishatuo Yangtze Railway Bridge, Luohuang Power Factory, No. 106 provincial highway, and so forth. In Jiangjin District alone, 41 square kilometres of urban land, with a population of over 400,000, would be flooded.

As a result, the cost of generating power at Xiaonanhai would be exceptionally high, more than 13,553 yuan RMB per kilowatt – much higher than the Three Gorges (4,950 yuan/ kW), Xiluodu (3,538 yuan /kW), and Xiangjiaba (5,749 yuan/kW) dams, all of which are less than 6,000 yuan/kW.

The construction of the Xiaonanhai will flood one of the richest and most densely populated
areas along the Yangtze valley, with plenty of arable land. Zhongbadao, where the dam will be located, for example, enjoys fertile soil and a moderate climate. The area produces 20,000 metric tonnes of vegetable crops a year, or up to 500 tonnes a day, and is a major provider of food to urban Chongqing. According to locals, “The average annual income for villagers in 2009 was 10,400 yuan (almost US$1,600), and some make more – 20 or 30 thousand per year. You can get rich on growing vegetables.”

The government of Chongqing has argued that one of the reasons to launch the Xiaonanhai dam is to satisfy power shortages in the municipality. But as Weng Lida, former director of the Yangtze Water Resources Protection Bureau, pointed out, that argument “is untenable.” The scale and speed of expansion of China’s electricity generation capacity in recent years is unprecedented. According to figures by the NRDC (National Development and Reform Commission), in 2010, China added a further 91.27 gigawatts of power-generation capacity – almost one tenth of total capacity at the end of 2010. Supply is already exceeding demand.

Another justification offered is that hydropower is “clean energy”, which can help to reduce greenhouse-gas emissions. In the majority of cases, emissions from hydropower stations are lower than from thermal stations, but hydropower, nevertheless, causes major environmental problems. Large dams damage aquatic ecosystems; cause or worsen geological disasters in the reservoir area; reduce the river flow; and cause water pollution in the reservoir area. Hydropower cannot be seen as a clean source of energy. The World Commission on Dams’ seminal 2000 report has already disproved the notion that hydropower is “green.” Achieving emissions-reduction targets cannot be done at the cost of even more serious environmental destruction.

Moreover, expanding hydropower will not necessarily reduce the use of thermal power or cut emissions. In the last decade, hydropower-generating capacity has skyrocketed as entire rivers in the west of China have been covered with cascades of dams. At the same time, investments in thermal-power capacity and coal consumption have all also increased rapidly. There has been both a slight rise in the percentage of hydropower and a slight rise in the percentage of thermal power in China’s overall energy supply. And there has certainly been no fall in the absolute amount of thermal capacity and associated carbon emissions. In fact, these two power sources have continued to increase together. In some provinces, where hydropower and its contribution to overall generation is increasing, backup thermal-power plants have also been built in order to provide power for times of peak demand and when the dry-season reduces hydropower output.

As Cao Wenxuan, China’s leading expert in fish, member of the Chinese Academy of Sciences and senior researcher at the Academy’s Wuhan-based Institute of Hydrobiology, pointed out, “While the Xiaonanhai dam is proposed to be built in the downstream section of the rare-fish conservation zone, the channel length available for fish migration would become shorter and shorter. From the point of view of protecting the population of fish in general and rare fish in particular, the migration channel should not be interrupted and no hydro dams should be built there. Even building a special channel would be ineffective because fish in the upper Yangtze are adapted to and thrive in a rapidly-flowing water environment.”

According to China’s Environmental Protection Act (Chapter 3, Article 17), “The people’s governments at various levels shall take measures to protect regions representing various types of natural ecological systems, regions with a natural distribution of rare and endangered wild animals and plants, regions where major sources of water are conserved, geological structures of major scientific and cultural value, famous regions where karst caves and fossil deposits are distributed, traces of glaciers, volcanoes and hot springs, traces of human history, and ancient and precious trees. Damage to the above shall be strictly forbidden.”

Based on China’s Regulations on Nature Reserves (Chapter III, Article 32), “No production installations shall be built in the core area and buffer zone of nature reserves. In the experimental zone, no production installations that cause environmental pollution or do damage to the natural resources or landscapes shall be built.”

Obviously, the redrawing of the reserve zone in the upper Yangtze was not intended to improve or enhance the structure and function of the reserve, but to make room for the Xiaonanhai dam by ignoring laws and regulations for the protection of the environment and natural reserve zone. Furthermore, doing so would clear the way for two more hydro dams proposed by the government of Chongqing, Zhuyangxi and Shipeng, resulting in the total removal of the rare-fish conservation zone as a whole.

The nation’s laws and regulations governing the nature reserve zone and environmental protection are seriously challenged once again, putting the last refuge for the rare fish on the upper Yangtze on the brink of ruin. I appeal to the government for public hearings and an administrative review of the issue, urge the authority to cancel the plan to build the Xiaonanhai power station on the Yangtze River, and call upon all people who are concerned about the environment and sustainable development to support and participate in the protection of aquatic life and ecosystems of the Yangtze valley.

I sincerely look forward to your review of the issue and to your wise and responsible decision with your wisdom, vision, courage and responsibility, at this critical moment for the rare fish reserve zone in the upper Yangtze. Protecting it would be a great blessing to the Yangtze River, to China and to the Earth!

Fan Xiao
(Chinese citizen, geological and environmental scholar and senior engineer)

February 2011

Further reading

Last ditch plea on Yangtze dam

Last refuge of rare fish threatened by Yangtze dam plans

China’s environment ministry said review needed for planned dam that threatens Yangtze fish

A response to the Ministry of Environmental Protection’s decision to suspend approval of hydro dam construction along the middle

Stop over-development of hydropower is the only way to save rare fish in the Yangtze

Top fisheries scientist wants upper Yangtze dams scrapped