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Environment Magazine September/October 2008

May-June 2011

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A Conflict of Greens: Green Development Versus Habitat Preservation – The Case of Incheon, South Korea

Boosting the economy in green ways is a goal for many nations, but not all agree on what “green” means; the efforts of the Republic of Korea (South Korea) include a range of policies under the framework of green growth, from a national stimulus plan to local city initiatives. In August 2008, President Lee Myung-bak proclaimed that “low-carbon green growth” (shortened to “green growth” here) would become the nation's new vision for overcoming the challenges of climate change and a looming carbon-based energy crisis while still continuing economic growth. South Korea's version of green growth is defined as “growth achieved by saving and using energy and resources efficiently to reduce climate change and damage to the environment, securing new growth engines through research and development of green technology, creating new job opportunities, and achieving harmony between the economy and environment.”1 In January 2009, President Lee's administration released a bold stimulus plan, called the “Green New Deal,” which included allocations for “green SOC” (social overhead capital), “low-carbon and highly efficient technologies”, and “environmentally friendly green living.” Six months later, the Presidential Committee on Green Growth released the “Five-Year Plan for Green Growth,” which incorporated the previous Green New Deal and outlined new national energy policies.2 The United Nations Environment Programme (UNEP) highlighted President Lee's plan as an example of South Korea's national Green Economy Initiative.3 Local (municipal) governments across South Korea also began to launch their own green city plans, incorporating comprehensive strategies to reduce carbon emissions.

In and around Incheon Metropolitan City (the nation's third largest city, with a population of 2.7 million, and hereafter shortened to “Incheon”), both the national and local governments have been planning several ambitious mega-scale projects. The two largest projects backed by the local government are the construction of the world's largest tidal power plant, to be called “Ganghwa Tidal Power Plant” (an artist's rendering of which is available at http://www.hec.co.kr/pr/news/news/view.asp?code=5040&page=8) and the master-planned “Songdo International City.”4 Begun in 2003 when civic and business leaders in Incheon were already looking ahead at an advanced “global business hub,” this project incorporates the latest principles in sustainable urban design, such as energy-efficient buildings and large green spaces. 5 (An artist's rendering is available at http://www.songdo.com/songdo-international-business-district/the-city/master-plan.aspx.) In December 2009, Incheon formally released the “Incheon City Low-Carbon Green Growth Plan,”6 which laid out various strategies for reducing carbon emissions, including building Ganghwa Tidal Power Plant and expanding the parks in Songdo International City. Meanwhile, the national Ministry of Land, Transport and Maritime Affairs (MLTM) announced plans to build its own mega-scale tidal power plant, “Incheon Bay Tidal Power Plant,” which would be 1.4 times larger than the Ganghwa Tidal Power Plant planned by Incheon.

Ironically, these local and national “green” initiatives planned in the Incheon area have raised a considerable controversy because they require the destruction of tidal-flat wetlands that host tens of thousands of migratory birds and are protected by national environmental laws. Ganghwa Tidal Power Plant would threaten the “Ganghwa Tidal Flat and Black-Faced Spoonbill Habitat,” which was designated as a Natural Heritage Site in 2000. Incheon Bay Tidal Power Plant would cut through the Jangbongdo Wetland Preservation Area, formally protected since 2003. Songdo Tidal Flat, where Songdo International City is being built, hosts at least 11 species of migratory birds in concentrations termed “internationally important” under the Ramsar Convention (1 percent or more of global population), including the black-faced spoonbill (Platalea minor). Those ecological values make the tidal flats in Incheon eligible for protection under the Ramsar Convention. Recognizing that these plans for national and local green growth are not compatible with preservation, the government of South Korea has been favoring growth by changing or removing protection from certain wetlands.

Caption: Black-faced spoonbills in Gaksibawi, Ganghwa, South Korea. Tidal power plants would damage their habitat.

Caption: Wetlands including tidal flats are excellent sites for environmental education in marine ecology, wildlife habitat, and ecosystem functions (Jangbongdo Wetland Protection Area, South Korea).

This article discusses the conflict between two different “green” approaches: “green development” (including the tidal power plants and the new city development) and “habitat preservation,” as they apply to the area of Incheon, South Korea. We also designate the former approach as “segmented green” and ask how South Korea and Incheon could pursue a more “systematic green” approach, from an environmental planning perspective. We investigate the ecological, economic, and social values that the current plans are missing. Also, we make suggestions for an alternative plan that fits growth into a framework of systematic greening using its local, natural, and cultural assets to boost the local economy. Given the crisis of climate change and dependence on fossil fuels, we expect that this conflict of “greens” will increasingly occur around the world, so we point out the implications for prudent policymaking and planning in comparable cases.

Green Growth, the New Vision for South Korea

Since 2009, when President Lee's administration set the new vision for the nation, the term green growth has become commonplace not only in various government policies but also in an overall South Korean society. Indeed, green growth appears to have supplanted “sustainable development,” which had been widely used in South Korea.

A broader vision of green growth began as a regional initiative of the United Nations Economic and Social Commissions for Asia and the Pacific (UNESCAP) at the fifth Ministerial Conference on Environment and Development in Asia and the Pacific in 2005.7 The main focus of green growth in this context was for developing countries in Asia and the Pacific region “to harmonize economic growth with environmental sustainability, while improving the eco-efficiency of the economic growth and enhancing the synergy between environment and economy… given the region's limited ecological carrying capacity and the enormous need for further economic growth to reduce poverty and meet the basic needs of its vast and expanding population.”8 Although poverty and expanding population are smaller concerns in South Korea9 than in other Asian and Pacific nations, the South Korean government joined the green growth initiative as a point of regional cooperation.

The preceding definition shows that green growth is not identical to sustainable development. While sustainable development is seeking a balance among economic growth, environmental projection, and social justice,10,11a strict definition of green growth does not address “social justice,” focusing rather on economic growth while reducing environmental impact.12 In this regard, green growth is a narrower or subordinate concept of sustainable development (Figure 1).13

Caption: Figure 1: Comparison between Sustainable Development versus Green Growth

Even in the two decades before President Lee began promoting green growth, South Korean society had been grappling with the concepts of sustainable development. Since Agenda 21 was declared at the Rio Earth Summit in 1992 and after South Korea joined the Organization for Economic Cooperation and Development (OECD) in 1996, internal and external forces have pushed South Korea toward sustainable development. Internally, South Koreans began to emphasize quality of life over simple reverence for rapid economic growth; civil society and social environmental grass-roots movements grew rapidly and began to ask the government to focus more on environmentally sound and sustainable policies. Externally, membership in the OECD, which some call “a rich countries' club,” meant that South Korea would no longer be able to claim “developing country” status as an excuse for its environmental pollution and social injustice. In response to these calls, in 2000, President Kim Dae-jung established the Presidential Commission on Sustainable Development.14 Still, South Korea's rate of carbon emissions growth was the highest among OECD countries between 1995 and 2005,15 so South Korea has been projected to be classified as an Annex I Party, a classification that requires a mandatory commitment to emissions reduction during the post-Kyoto regime.16 Given this challenge, in 2009, South Korea set the aggressive goal of voluntarily reducing greenhouse gas (GHG) emissions by 30 percent by 2020: the greatest reduction that the IPCC (Intergovernmental Panel on Climate Change) has recommended for non-Annex I countries.17

The strength of South Korea's voluntary commitment to reducing GHG emissions and mitigating global climate change should be welcomed by global society, but there are several points of criticism on whether shifting from sustainable development to green growth represents progress or regression for society as a whole. First of all, due to the narrower definition of green growth that excludes “social justice,” many green growth policies consider neither whom the growth is for nor whether they are transforming a social structure toward a sustainable society, but focus only on achieving a reduction in GHGs through technological development and economic growth.18 Some critics doubt even whether green growth policies are meeting their defined and stated goal of environmental sustainability. As a striking example, the “Four Major Rivers Restoration Project” (Four Rivers Project), the largest component of South Korea's Green New Deal, with a total budget of US$19 billion, has been receiving nationwide attention and criticism from the public, environmentalists, and scholarly groups due to its huge scale (four major rivers in South Korea) given the short project term (2009–2012), the use of controversial construction methods (large-scale dredging and dam construction), and its top-down manner in the process of decision making and environmental impact assessment.19 As for the green energy policies, the core priority of the current energy plan is the expansion of nuclear power generation,20 an energy supply with low carbon emissions but not universally regarded as “clean” or “green” because of its ancillary environmental impacts.21 The worldwide debate over nuclear power has become particularly heated, following the explosions and near-catastrophic failure at several nuclear power plants in Japan caused by the Tōhoku earthquake and tsunami of March 2011.

Conflicts of “Greens” in Incheon, South Korea

Tidal Power Plants on the Natural Heritage Site and the Wetland Preserve?

Like nuclear power, large-scale tidal power generation is the subject of another “green” energy controversy. As a source of power not derived from fossil fuels, tidal power generation (broadly under the category of “ocean energy”) is one of the keys to South Korea's initiatives for enlarging its renewable energy supply. According to “Green Energy Industry Development Strategies” prepared by the Ministry of Knowledge and Economy in September 2008, various agencies within South Korea plan to build a total of six tidal power plants along its western coast (Figure 2). In brief, this model of power plant (tidal barrage) surrounds a shallow expanse of the sea with a gated sea wall; the rising tide flows in, the gates are closed at high tide, the tide ebbs outside the expanse to create a differential in water levels, and then water is released through turbines at controlled outlets to generate electricity.22 A partnership at the national level—the Ministry of Land, Transport and Maritime Affairs (MLTM) and Korea Hydro and Nuclear Power—plans to build the largest plant, Incheon Bay Tidal Power Plant (TPP). About 3 km north of this plant's sea wall, a second partnership between Incheon City and Korea Midland Power Corporation plans to build another tidal power plant, Ganghwa23 TPP. The estimated 2,413 GWh to be generated each year at Incheon Bay TPP and 1,536 GWh at Ganghwa TPP could satisfy 60 percent and 43 percent, respectively, of today's residential electricity demand in Incheon; in other words, “clean” electricity from these two plants could run all households in Incheon. (These figures are for illustration only, as the power plants would not necessarily serve only residential users.) A third plant, Sihwa TPP, about 25 km south of Incheon Bay TPP, was recently completed and is registered as a Clean Development Mechanism (CDM) project under the United Nations Framework Convention on Climate Change (UNFCCC). It is the highest capacity tidal power plant in the world and is expected to reduce 315,440 metric tons of CO2 equivalents per year.24

Caption: Figure 2: South Korea's plans for ocean energy generation, showing capacities of tidal power plants (Haeju Tidal Power Plant would be located in North Korean territory; its capacity is not available).

Tidal power generation appears to be the perfect “green” renewable energy; however, like many other energy sources, it requires trade-offs at the local, national, and global scale (Table 1), especially when it is planned at a scale as large as these three Korean projects. In spite of the projected benefits of reducing carbon emissions for mitigating global climate change, various environmental nongovernmental organizations (NGOs)—local, national, and international—and local fishermen's groups strongly oppose the tidal power plants. Those groups anticipate deep and lasting harm to the tidal flat ecosystem, fisheries, culture, and landscape (Figure 3).

Table 1: The tradeoffs of tidal power projects between local, national, and global goals toward climate mitigation


PROS

CONS

Local

  • Secure, non-polluting energy supply
  • Jobs (short-term: construction; long-term: operations/management and technical support)
  • Destruction of ecosystem
  • Decline of local fisheries and related jobs (long-term)
  • Lost opportunity for eco-tourism and related jobs (long-term)
  • Increased risk of flooding
  • Impact on natural landscape

National

  • Achievement of GHG reduction goals
  • Fiscal saving from reducing fossil fuel imports
  • Immediate stimulation of employment
  • Large initial cost for construction
  • Decline or extinction of legally protected species
  • Decline of fisheries and eco-tourism along the west coast and associated possible long-term net loss in employment
  • Disruption of tidal processes in Yellow Sea

Global

  • Mitigation of global climate change
  • Decline of biodiversity
  • Destruction of globally unique ecosystems and natural landscapes

Caption: Figure 3a: Satirical cartoon from a local artist criticizing Ganghwa Tidal Power Plant. People from Daewoo Construction Company, Ganghwa County, Incheon City, and Korea Midland Power Corporation are pushing a fisherman out of a boat named “Tidal Power Plant Development”, while telling him “Everything will be fine if only you drown in the water!”

Caption: Figure 3b: In the museum, a teacher says to her students, “These are the organisms that used to live in Ganghwa Tidal Flat.” The displays include river puffers, swimming crabs, large-eyed herring, akiami paste shrimp, and a fisherman.

The current plan for Incheon Bay TPP would impact a tidal flat that is protected under the law (Figure 4). In 2003, MLTM designated the Jangbongdo Tidal Flat as a Wetland Preservation Area (68.4 km2, the largest of Korea 's Wetland Preservation Areas). Furthermore, when South Korea hosted the 10th Meeting of the Conference of the Contracting Parties (COP10) of the Ramsar Convention in 2008, MLTM began to prepare a request for Ramsar registration of Jangbongdo on the grounds that it provided habitat for rare water birds, including breeding sites for the Chinese egret (Egretta eulophotes, natural heritage no. 361) and eastern oystercatcher (Haematopus ostralegus osculans, natural heritage no. 326), provided habitat for various marine life, and had a unique geomorphology with high tidal ebb and flow and a vast delta.25 Despite this ecological value, MLTM has been hesitating to submit the request in that Incheon Bay TPP would encroach onto 24.7 km2 of the Jangbongdo Wetland Preservation Area.

Caption: Figure 4: The current plan for tidal power plants conflicts with a natural heritage site (No. 419) and wetland preservation area (No. 5).

The area designated “Ganghwa Tidal Flat and the Black-Faced Spoonbill Habitat,” where Ganghwa TPP is proposed, has been protected as a Natural Heritage Site (no. 419) since 2000. It is South Korea's largest natural heritage site (370 km2) and is one of the nation's few tidal flats that is soundly preserved. Ganghwa Tidal Flat, along with the Han River estuary and other tidal flats near Incheon, hosts tens of thousands of migratory birds that travel along the East Asian–Australian Flyway. The small, rocky islands of this area are critical breeding grounds for the black-faced spoonbill (Natural Heritage no. 205, an endangered wildlife species of the Ministry of Environment, and classified as “Endangered” by the IUCN), whose world population was recorded at 2,065 in a 2008 winter census26.

NGOs are outraged because of the way the government's policies are affecting tidal flat wetlands. Destroying vital tidal flats, the NGOs argue, violates not only domestic laws but also international agreements to protect wetlands, such as the Ramsar Convention (Resolution X.22),27 signed by South Korea in 2008. The government's policy directly contradicts President Lee's statement at the Ramsar COP10 at Changwon (October 2008), that South Korea would be exemplary among the parties to the Ramsar Convention and would constantly increase Wetland Preservation Areas and Ramsar-registered wetlands.28

Countering these NGOs, MLTM claims a precedent to rescind natural heritage sites, saying that canceling wetland preservation would be justified when the public interest is at stake29. In order to evade conflicts between the tidal power plants and the Ramsar registration, MLTM is considering submitting a request for Ramsar registration of a smaller portion of the Jangbongdo wetlands and is considering canceling and redesignating the Wetland Preservation Area to accommodate the tidal power plant.30 In 2010, the national government invoked this clause at Baweenupgoobi wetland, a critical habitat for natural heritage and endangered plants and animals, to allow dredging for the controversial Four Rivers Project.31

Other factors besides wetland destruction call into doubt whether large-scale tidal power is an environmentally friendly way to generate energy. Its large reduction of GHG emissions makes tidal power generation appear more attractive than conventional systems (using fossil fuels) or even than other kinds of distributed renewable energy systems (such as rooftop solar panels and micro-scale wind turbines). However, most potential sites for tidal power plants around the world, including in South Korea, are unique marine ecosystems and habitats for migratory marine animals and shorebirds.32 Even when tidal power plants seem economically feasible, they create ecological disturbances whose economic costs may be difficult to determine: reductions in salinity, currents, and water exchange, as well as modifications to tidal flats.33 Up to now, only a few large-scale tidal power plants have been built and operated worldwide (in France, Russia, and Canada; small-scale plants have been built in China).34 A few countries have started pursuing large-scale tidal power projects, including the United Kingdom at its Severn Barrage,35 one of the world's most ambitious renewable-energy plans, but that project also received enormous criticism from environmental NGOs such as the National Trust, Royal Society for the Protection of Birds (RSPB), World Wildlife Fund (WWF), and the Angler's Trust.36 Furthermore, the British government's revised cost estimate was US$54 billion, more than twice much as its initial estimate (US$24 billon). Due to this projected high cost and risk, in November 2010, the British government finally decided to withdraw its support for the Severn Barrage, even though it could have produced 5 percent of the United Kingdom's electricity37.

Incheon shows an extreme case of the controversy between renewable energy generation and habitat preservation because of a new national policy on energy. South Korea adopted a Renewable Portfolio Standard (RPS) in 2010, requiring utility companies to generate a certain portion of energy from renewable resources: about 2 percent (1,474 MW) by 2012 and 8 percent (6,648 MW) by 2020. Due to this urgent pressure, utility companies are swarming over Incheon Bay, which appears ideal for one or more large-scale tidal power plants38. Three plants—each one having a capacity greater than that of the Rance Tidal Power Station in France (240 MW), formerly the world's largest—have been proposed within a distance of 60 km. (The largest of the three, the nationally backed Incheon Bay TPP, would have a capacity of 1,320 MW, or 5.5 times that of Rance; the 840-MW locally backed Ganghwa TPP would be like 3.4 Rances, and even the smallest of the three, the 254-MW Sihwa TPP, just replaced Rance as the largest in the world.) Environmental NGOs and experts have also brought up potential problems such as flooding, instability of electricity supply, and damage in landscapes due to transmission facilities.39 No environmental impact assessment has investigated the cumulative impact of these three plants, though it would undoubtedly be significant.

Conflict is now brewing between Incheon's local government and the national government. The new mayor of Incheon, Young-Gil Song, elected in June 2010, is considering canceling Ganghwa TPP (the local partnership's project) or shrinking its capacity by half (from 840 MW to 420 MW) and he expressed his opposition to the Incheon Bay TPP (the national project). Nevertheless, MLTM still pursues the Incheon Bay TPP as a green growth policy. NGOs censure this, saying that it shows another departure from President Lee's message at the Ramsar COP10, as he said that the national government would actively support local governments' efforts to preserve wetlands.40

Another debate in tidal power generation is the economic value of tidal flats, because this value is central to the decision-making process. In the current cost–benefit analysis of Ganghwa TPP, the cost of environmental impact on the tidal flat is missing.41 The analysis for Incheon Bay TPP cited a cost of tidal flat loss from the 1997 research of Costanza et al. (US $9,990/ha/year, assuming US $1 = KRW 1,200),42 but tidal flats in Korea seem to have a greater value than the global average estimated by Costanza. According to a 2006 study by the Korean Ocean Research and Development Institute, the average value of Korean tidal flats estimated from 13 other Korean studies was US $32,660/ha/year43 (the largest contributor being fisheries), roughly three times larger than the Costanza estimate. A recent evaluation on tidal flats in Incheon indicates even higher values. The Mang et al. study from the Korea Environment Institute in 2007 argues that the conventional estimates of the value of tidal flats were significantly low: The tidal flats around Incheon provided $27,972/ha/year of benefits for purification alone,44 7.6 times greater than the 2006 Korean Ocean Research and Development Institute's study. The Korea Environment Institute also estimated the carbon reduction by tidal flats at about 10 tons/ha/yr, with a value of about KRW 34,000,000/ha/yr (US$28,300/ha/yr). This value is 2.8 to 9.5 times greater than the range (KRW 3,600,000 to 12,000,000) estimated by Ministry of Maritime Affairs and Fisheries in 2005.45

Due to uncertainties and limitations in the evaluation methods, the range of the estimates varies greatly. Scientists and economists therefore urge that the economic valuation of ecosystems be regarded as a minimum estimate only.46 Furthermore, environmentalists argue that it is a matter of ethics, not merely economics, when human activity threatens the existence of species and their habitats. This debate could go on endlessly, but it is clear that estimates of the value of tidal flats have been increasing as scientists understand more about the vital role that tidal flats play in sustaining urban areas as well as marine ecosystems. The current decision-making processes regarding tidal power plants in South Korea, however, do not thoroughly incorporate these values of tidal flats.

The World's Greenest City on Endangered Bird Habitat?

The Incheon Free Economic Zone (IFEZ), which includes Songdo International City, is one of the most ambitious endeavors in Incheon's 128 years of urban planning history.47 Economic and environmental goals for Songdo International City are similar to those of the national government's plan for green growth, though the city is not formally included in those national plans. Aiming at being a global business hub, Songdo International City consists of 11 sections with various land uses, such as businesses, residential, commercial, educational, industrial, high-tech research, and parks (Figure 5). Construction on Songdo International City began in 2003, and Sections 1 to 10 have been filled or are under construction as of this writing. Section 1 and Section 3, in particular, are being developed by United States-based developer Gale International and architectural firm Kohn Pedersen Fox as the Songdo International Business District (IBD), “one of the world's greenest cities”48 consisting of energy-efficient buildings certified under the standards of LEED (Leadership in Energy and Environmental Design).49 Songdo IBD is also seeking certification under the pilot program for LEED-ND (Neighborhood Development),50 which evaluates the city's urban design based on such principles as pedestrian connectivity, transit accessibility, energy-efficient building, infrastructure design, open space, and wildlife habitat preservation. About 40 percent of Songdo IBD is planned as green space, including a 100-acre (40-ha) central park and Jack Nicklaus Golf Club.51 This master plan (shown above) won the Sustainable Cities Award in 2008 sponsored by the Financial Times and the Urban Land Institute.52

Caption: Figure 5: Songdo Master Plan

This “green master plan,” however, required filling Songdo Tidal Flat, an important stopping ground for many migratory birds, including natural heritage species such as the black-faced spoonbill and eastern oystercatcher. According to the NGO Birds Korea, Songdo Tidal Flat hosted 13 species of waterbirds in Ramsar-defined internationally important concentrations (more than 1 percent of the global population) in 2001, but two of them were no longer recorded in such concentrations in 200653 after most of the tidal flats were filled. Local environmental NGOs and citizens' groups have campaigned against further filling of tidal flats in Songdo more actively since 2009, when black-faced spoonbills began nesting and breeding on an artificial island in an industrial-drainage pond near Sections 11, where the last phase of the filling has already been approved (Figure 6).

Caption: Figure 6: Human settlements have been encroaching on the tidal flats where the birds forage. The small dot in the Namdong industrial-drainage pond is an artificial island that locals call “Black-faced Spoonbill Island”, because black-faced spoonbills have been nesting and breeding there since April 2009. This island is surrounded by 5,000 factories, apartments, office buildings, and newly filled (“reclaimed”) land without buildings yet. To the left of the newly filled land is “Section 11”, the last remaining tidal flat in Songdo, where further filling has been approved.

Incheon has been filling, or “reclaiming,” its coastal wetlands since 1883 with Incheon's birth as a port city, and reclamation has significantly increased as Incheon has grown over the twentieth century (Figure 7).54 The total area of reclaimed land from 1883 to 1999 was about 134 km2 (as shown earlier), and this figure has increased since 2000, especially in Songdo (Figure 8). As the ecological and economic value of tidal ecosystems began receiving more attention, Incheon established its “Charter for Tidal Flat Preservation” in 2000 and committed to preserve its valuable tidal flats, but in fact, Incheon recorded the largest loss of tidal flats among South Korean localities from 2003 to 2008—33.2 km2, out of a total national loss of 60.8 km2.55 What's more, 47.7 km2 of tidal flats are planned to be filled in the next 10 years—Section 11 in Songdo (6.91 km2), rear sites of the new port (3.7 km2), new dumping sites for dredged soils (7.9 km2), Ganghwa Tidal Power Plant (7.65 km2), and Incheon Bay Tidal Power Plant (22.3 km2).56

Caption: Figure 7: Incheon Reclamation History

Caption: Figure 8: Songdo Shoreline Change: Songdo Tidal Flat was called “Meon-eoh-geum” () which meant “endlessly far.” It was famous for clean water and enormous fish diversity; the highest-quality surf clams in South Korea were produced here. This golden fishery is now gone because of Incheon's large-scale reclamation projects.

International societies have begun to realize South Korea's inconsistency in wetland preservation. On September 21, 2009, the Financial Times (a sponsor of the Sustainable Cities Award for Songdo International City in 2008) accused South Korea's large-scale reclamation and Four Rivers Project of destroying precious wetlands and endangered bird habitat, in its special report “Green New Deals: Regional Solutions.”57 Since Songdo is prime habitat for birds that migrate along the East Asian–Australasian Flyway, environmental NGOs and scientists along this flyway, such as Birds Australia, Australasian Wader Studies Group (AWSG), and SAVE International, have expressed serious concerns about the filling at Songdo and have urged Incheon to withdraw the approval to fill Sections 11.58 This is a fierce war of ideas, between governments that dream of a sustainable city on this new green space and environmental NGOs that see sustainability in maintaining a boundary on human settlement and preserving the habitats of endangered species.

Another question is whether Songdo IBD can be certified as a “sustainable neighborhood” under LEED-ND. The developers of Songdo IBD enrolled it as a pilot project of LEED-ND,59 but final certification of pilot projects is not assured. Even though Songdo IBD would earn many points toward certification for some sustainable urban design practices, it fails to meet the prerequisites of the “Smart Location & Linkage” category: It is being built on a filled wetland and it does not address the habitat requirements of the endangered bird species as rigorously as the LEED-ND guidelines require.60 Indeed, the status of Songdo IBD's certification in the pilot program is unclear: The latest list of pilot projects as of January 5, 2011, no longer includes Songdo IBD, but one project “has requested to be confidential and not be included on this list.”61

What Environmental Planners Recommend to Incheon and South Korea

Considering several major theories and practices in environmental planning, it is not clear that these “green” plans occurring in Incheon reflect the best practices for truly green development. Ian McHarg, a pioneer of ecological urban and regional planning, emphasized that ecologically determined planning is the best way of achieving efficient and cost-effective development, since nature would provide the majority of human needs, and costs necessary for adaptation would be minimized.62 However, the cases of Incheon and South Korea do not show integration of adaptation costs in their decision making.

Other scholars in ecological design, such as Michael Hough,63 Anne W. Spirn,64 Judy and Michael Corbett,65 John Lyle,66 Nancy and John Todd,67 and Sim Van der Ryn,68 commonly emphasized that the best practices of ecological design pursue a comprehensive and long-term approach that follows the cycles of natural processes and integrates diversity, complexity, and interconnection of human societies and ecosystems across the time and spatial scales. This approach could be called “systematic green.” However, the current “green” efforts in South Korea seem to be a piecemeal approach, improving part of an environmental problem at one scale but causing other ecological or social problems at another scale. In contrast to the “systematic green” approach, this approach can be called “segmented green.”

In light of the “systematic green” approach, preserving tidal flats would be more economically beneficial for Incheon in a long-term perspective. G. Mathias Kondolf, a geomorphologist and professor in environmental planning at the University of California, Berkeley, asked in an open letter to Ahn Sang-soo, the former mayor of Incheon, why Incheon was about to make the same mistakes other developed countries had made: “In the San Francisco Bay Estuary, the state and federal governments have spent hundreds of millions dollars since 1996 on projects to restore tidal wetlands but we have restored about one percent of the lost wetlands to date. While it is difficult and expensive to reverse the mistakes made in the past before we fully understood the important role of tidal wetlands, it is tragically unacceptable to make the same mistakes today, given our improved understanding of tidal wetlands ecosystems.”69 Thirty years from now, Incheon and South Korea might be spending even greater amounts of taxpayer money to restore the tidal flats that are being destroyed today.

Tidal flats in Incheon play a significant role in not only supporting marine ecosystems and migratory birds but also sustaining the quality of the urban environment. Research by the Korea Environment Institute in 2007 concluded that the purification capacity of the tidal flats south of Incheon International Airport (157 km2)—just west of Songdo—was equivalent to that of 31 sewage-treatment plants, each one reducing 20.19 tons O2/day in chemical oxygen demand (COD) and having an average construction cost of $99,167,000 and yearly maintenance costs of $3,083,000.70 If Incheon continues to fill tidal flats, it needs to account for the costs of new artificial systems to replace these lost natural benefits.

Besides preserving natural benefits, the creation of new wetland parks and aquatic systems for sewage treatment would further help Incheon reduce water pollution by utilizing ecological engineering techniques and would enhance the area's unique landscapes. As a “regenerative” system, in the words of leading ecological designer John Lyle, constructed wetlands at strategic locations in an urban drainage system would provide “landscapes” (as opposed to simple “facilities”) that treat urban runoff and sewage in an ecological way.71 It would be especially useful for the water treatment to be visible,72 so people could appreciate the chemical and biological processes. Such facilities could serve multiple functions—places for environmental education for nearby schools and campuses, habitat for wildlife, and sites for ecotourism. Also, the provision of wetland parks would allow people in Songdo to connect to their indigenous “sacred landscape,” tidal flats.73 But the current plan missed those opportunities and makes a generic waterfront city that could be anywhere in Asia.

Ecotourism is the greatest opportunity that a green Incheon must not overlook. In the “systematic green” scheme, bird habitat is not a barrier for city development, but an opportunity to build a green city and provide residents and visitors with an experience of enjoying nature. On the southern coast of South Korea, Suncheon Bay Ecological Park attracts many tourists eager to see birds, marine micro-animals, reed fields, and tidal flats.74 Like Songdo, Suncheon Bay is one of the critical wintering habitats of rare and endangered migratory birds and it is the only place in South Korea that hosts the hooded crane (Grus monacha, natural heritage no. 228). Due to its habitat value, Suncheon Bay Ecological Park was designated as a Wetland Preservation Area in 2003 and registered under the Ramsar Convention in 2006.

After Suncheon City began to foster preservation and ecotourism, tourists have constantly increased, even as the birds' population and diversity increased. In 2008, 2.6 million tourists visited, which was 70 percent more than the previous year.75 Songdo has even greater potential to become a special place with a combination of high-tech and unique environmental assets, as well as high accessibility from the Seoul and Incheon metropolitan areas, where city dwellers are eager to see nature. Songdo is known as the only site where people can closely observe the breeding behaviors of black-faced spoonbills in an urban area, since their nests are usually on remote, rocky islands.

As for the green energy controversy, reconsidering the plans for the tidal power plants at Ganghwa and Incheon Bay seems appropriate at this moment of nascent technology of tidal power and unprecedented scale of the proposed project. In order to mitigate global climate change by minimizing the use of fossil fuel, some nations may find ocean energy to be a feasible option, but as the United Kingdom's rejection of the Severn Barrage shows, today's technologies still hardly meet economic feasibility while minimizing environmental impacts. New technologies for ocean energy—tidal power, wave power, and current power—are being researched around the world; as technologies develop, perhaps a different technology and/or scale for tidal power could meet South Korea's demands in the future. Sihwa Tidal Power Plant, on the other hand, appears to be an acceptable compromise of development and environment; Sihwa Lake has suffered from poor water quality due to diking since 1994, but the tidal power operation would provide greater circulation and flushing and should improve the water quality.76 However, the two additional tidal power plants of unprecedented size within 60 km of Sihwa may exceed the environmental carrying capacity of the tidal flats and have a significant impact on marine ecosystems, endangered birds, and local fisheries.

If the genuine intent of green growth is to minimize environmental impacts while promoting economic growth, a more appropriate solution than building a few mega-scale power plants (especially in critical ecosystems) would be to foster a distributed system of micro-scale renewable energy generation and to promote energy conservation or other forms of demand-side management. For example, given similar conflicts between large-scale solar farms and desert ecosystems in the United States, the U.S. Bureau of Land Management and six southwestern state governments recently implemented new regulations that restrict the development of large-scale solar energy generating facilities in critical ecosystems in order to minimize habitat loss and to mitigate the associated harmful environmental impacts.77 In order to resolve conflicts among green policies, South Korea and any countries that want to harvest renewable energy should also consider implementing such regulations to protect wildlife habitat from large-scale energy development, even though the energy itself is “renewable.”

Conclusion: Toward Systematic Green

In this era of climate change and ecological awareness, no government is likely to be able to craft policies without considering the long-term ecosystem functions. The perennial debate between economic development and natural preservation has now shifted toward a more subtle conflict between “systematic green” and “segmented green.” This war over “green” concepts will occur more and more around the world in the twenty-first century, and it will be important to use science and long-term planning to help guide policies.

In many cases, some negative environmental impacts must be accepted under even the greenest of policies, but these impacts must be counted as costs of the policy. If South Korea is willing to pursue “systematic” green growth instead of “segmented” green growth, it may need to reassess the costs of the current plans for tidal power plants and tidal flat reclamation, reevaluate whether those plans are still economically feasible, and balance the goals of a sustainable local, national, and global society in the long run. Formal procedures to assess the environmental impacts of future proposed projects—especially on scales as large as those of the tidal power plants and Songdo International City—must take on a broader systematic outlook, such as considering a wider range of alternatives, allowing more time for thorough review by the local community and by relevant experts (local, national, or international) and then addressing their suggestions fairly; government officials, in turn, should give more weight to these assessments in their ultimate decision to pursue or forgo a project.

In a “systematic green” society, ethical development receives greater emphasis; a decision for development is not based merely on economics but also on cares for future generations and other species. Sixty years ago, renowned conservationist Aldo Leopold argued, “Birds should continue as a matter of biotic right, regardless of the presence or absence of economic advantage to us.”78 Leopold's “land ethics” could serve as another essential criterion to evaluate whether “green” policies are truly responsible in the ecological sense, whether in Incheon, other parts of South Korea, or the rest of the world.

Green growth and habitat preservation are not always mutually exclusive (Figure 9). It is possible to plan for green growth according to the precepts of Ian McHarg, Aldo Leopold, and other environmental planners. Such plans, however, would require careful consideration of each specific site. Planning and support from the central government must reflect and respect the latest scientific research as well as the firsthand experience of local residents. Creating and enacting plans that truly live up to their “green” claims will be a contentious but stimulating challenge to scientists, planners, policymakers, and everyday citizens alike, in this century and beyond.

Caption: Figure 9: Songdo “Green” City and shorebirds: must they be mutually exclusive?

1. Framework Act on Low Carbon, Green Growth of 2010, Law 9931, 14 April 2010, Republic of Korea.

2. Presidential Committee on Green Growth, Five-Year Plan for Green Growth (2009–2013) (Seoul, Republic of Korea, 2009), http://www.greengrowth.go.kr/www/green/tenpolicy/ohplan/plan1.cms (accessed 10 January 2011).

3. United Nations Environment Programme (UNEP), Overview of the Republic of Korea's National Strategy for Green Growth (Geneva, Switzerland: UNEP, April 2010), http://www.unep.org/PDF/PressReleases/201004_unep_national_strategy.pdf (accessed 17 July 2010).

4. Songdo International City (also called Songdo International Business District, IBD) is not officially part of South Korea's plans for green growth but we include it under the label of “green development.” Songdo IBD is one of the three IBDs—Yeongjong, Cheongna, and Songdo—in Incheon Free Economic Zone (IFEZ). With US$41 billion of government investment, IFEZ aims at becoming a business hub of Northeast Asia by accommodating advanced technologies and capitals in South Korea. Out of a total area of 209 km2 (around one-third of Seoul or Singapore), about 73 percent is “reclaimed” former tidal flats. Incheon Free Economic Zone (IFEZ), IFEZ, http://eng.ifez.go.kr (accessed 3 June 2010).

5. Songdo IBD, Sustainable City, http://www.songdo.com/songdo-international-business-district/why-songdo/sustainable-city.aspx (accessed 8 June 2010).

6. Incheon Metropolitan City, “Incheon City Low Carbon Green Growth Plan for the World Best Green Incheon,” press release (through Incheon TV News Network) (Republic of Korea, 10 December 2009).

7. United Nations Economic and Social Commissions for Asia and the Pacific (UNESCAP), Green Growth—environmentally sustainable economic growth for the well being of all, http://www.greengrowth.org (accessed 10 July 2010).

8. Ibid.

9. According to the United Nations Development Programme (UNDP) Human Development Index (HDI, a composite measure of the nation's status of well-being using health, education, and income data) of 2010, South Korea is ranked in 12 out of 169 countries. The HDI of South Korea is 0.877, far above the averages for the region (East Asia and the Pacific: 0.650) and the world (0.624). It is accessible at http://hdrstats.undp.org/en/countries/profiles/KOR.html (accessed 20 January 2011). South Korea's National Statistical Office (NSO) reported that the fertility rate among women 15 to 49 was 1.15 in 2009, which is one of the lowest birth rates in the world. This information is accessible at http://www.index.go.kr/egams/stts/jsp/potal/stts/PO_STTS_IdxMain.jsp?idx_cd=1428 (accessed 20 January 2011).

10. S. Connelly, “Mapping Sustainable Development as a Contested Concept,” Local Environment 12, no. 3 (2007): 259–278.

11. G. Myerson and Y. Rydin, The Language of Environment: A New Rhetoric (London: UCL Press, 1996)

12. S. Yun, “The Ideological Basis and the Reality of Low Carbon Green Growth,” ECO 13, no. 1 (2009): 219–266.

13. Ibid.

14. After President Lee established the Presidential Committee on Green Growth (http://www.greengrowth.go.kr/english/en_main/index.do) in 2009, the Presidential Commission on Sustainable Development was reorganized as the Korean National Commission on Sustainable Development (http://www.pcsd.go.kr/eng/index.html) under the Ministry of Environment.

15. C. Oliver, “New Development Bites the Hand that Feeds Eco-tourism,” Financial Times, September 21, 2009.

16. J.K. O'Donnell, The U.S.-ROK Alliance: A Catalyst for Green Growth? (Washington, DC: Center for U.S.–Korea Policy, The Asia Foundation, March 2010), http://asiafoundation.org/resources/pdfs/ODonnellGreenGrowth.pdf (accessed 17 July 2010).

17. United Nations Environment Programme (UNEP), note 3.

18. Yun, note 12.

19. For more details, see D. Normile, “Restoration or Devastation?,” Science 327, no. 5973 (March 26, 2010): 1568–1570.

20. According to the Presidential Committee on Green Growth's 2009 report “Strategies for Energy Goal Management and Clean Energy Expansion,” “Expansion of Nuclear Energy” is first included in the subordinate chapter of “Expansion of Clean Energy Supply” prior to renewable energy. The report is at http://www.greengrowth.go.kr/resource/new_images/policy/02_sin02.pdf (accessed on 13 January 2011). From the fiscal aspect, in the budget for green technology, the development of nuclear fusion technology was assigned to the highest ratio (34.9%) in 2008, and it became even larger (35.8%) in the 2009 budget. On the contrary, the development of renewable energy technologies occupied only 19.2% in 2008 and decreased even more to 18.5% in 2009; Yun, note 12.

21. Yun, note 12.

22. Wikipedia, Tidal barrage, http://en.wikipedia.org/wiki/Tidal_barrage (accessed 14 January 2011).

23. Ganghwa is an island (Ganghwa-do) and a county within Incheon Metropolitan City.

24. United Nations Framework Convention on Climate Change (UNFCCC), Project 0349: Sihwa Tidal Power Plant CDM Project, http://cdm.unfccc.int/Projects/DB/DNV-CUK1143710269.08 (accessed 27 July 2010).

25 Ministry of Land, Transport and Maritime Affairs, “South Korea Is Increasing Ramsar Registered Wetlands Twice More,” press release (Seoul, Republic of Korea, 3 November 2008)

26. S. Chan, W. H. Fang, K.S. Lee, Y. Yamada, and Y.T. Yu, International Single Species Action Plan for the Conservation of the Black-faced Spoonbill (Platalea minor), CMS Technical Report Series No. 22 (Cambridge, UK: BirdLife International and the Convention on the Conservation of Migratory Species of Wild Animals (CMS), 2010), http://www.cms.int/publications/TechSeries/ts22_black_faced_spoonbill.pdf (accessed 5 June 2010).

27. Ramsar Convention, Resolution X.22 (Changwon, Republic of Korea: Ramsar Convention, November 4, 2008), http://www.ramsar.org/pdf/res/key_res_x_22_e.pdf (accessed 30 July 2010).

28. Korean Federation for Environmental Movement (KFEM), “President Lee's Congratulatory Message for Ramsar COP Is a Fraud. Annul the Coastal Reclamation and the Canal Plans,” press release (comment) (Republic of Korea, 29 October 2008). KFEM is the largest national environmental NGO in South Korea and a member of the global NGO Friends of the Earth. KFEM was established in 1993 when eight Korean environmental NGOs united, and now has 52 local offices around South Korea.

29. Wetland Conservation Act of 1999, Law 5866, 8 February 1999, Republic of Korea. Under the current Wetland Conservation Act, “With an executive order, it is possible for the Minister of MLTM, local mayors, and governors to rescind and/or shrink the wetland preservation area in case of public interests and military purposes.”

30. Ministry of Land, Transport and Maritime Affairs, Environmentally-Friendly Development Strategies for Incheon Bay Tidal Power Generation, internal report (Seoul, Republic of Korea, March 2009).

31. Normile, note 19.

32. M. J. Dadswell and R. A. Rulifson, “Macrotidal Estuaries: A Region of Collision Between Migratory Marine Animals and Tidal Power Development,” Biological Journal of the Linnean Society 51, no. 1 (1994): 93–113.

33. R. H. Charlier, “Sustainable Co-generation From the Tides: A Review,” Renewable and Sustainable Energy Reviews 7, no. 3 (2003): 187–214.

34. Ibid.

35. Ministry of Land, Transport and Maritime Affairs, “South Korea Is Increasing Ramsar-Registered Wetlands Twice More,” press release (Seoul, Republic of Korea, 3 November 2008).

36. J. Vidal, “Severn Tidal Power Shortlist ‘Biased’;, Campaigners Say,” guardian.co.uk, 8 May 2009, http://www.guardian.co.uk/environment/2009/may/08/severn-estuary-tidal-scheme?intcmp=239 (accessed 14 July 2010).

37. B. Dorminey and The Daily Climate, “Testing the Waters with Tidal Energy,” Scientific American, 6 December 2010, http://www.scientificamerican.com/article.cfm?id=testing-the-waters-with-tidal-energy (accessed 29 January 2011).

38. H.R. Park, “Ganghwa Tidal Power Plant, What Is the Problem?,” Environment and Life, Spring 2010 (Vol. 63), 204–220.

39. Ibid.

40. Korean Federation for Environmental Movement (KFEM), note 28.

41. Incheon Metropolitan City et al., Master Plan for Ganghwa Tidal Power Plant Joint Development Project, internal report (Republic of Korea, May 2007).

42. R. Costanza et al., “The Value of the World's Ecosystem Services and Natural Capital,” Nature 387 (September): 253–260.

43. The estimated annual value of a hectare of Korean tidal flats (US $32,660) includes marine products ($9,993), ecosystem preservation ($8,548), habitat ($7,533), water purification ($3,702), recreation ($1,443), and disaster prevention ($1,442). This estimation is from the Ministry of Maritime Affairs and Marine Products, “Coastal Wetlands Conservation Plan,” presented at the Symposium for Tidal Flat Conservation and Sustainable Use, Gochang, Republic of Korea, 28 September 2006.

44. J. H. Mang et al., Improving Environmental Assessment in Tidal Flat Reclamation (Seoul, Republic of Korea: Korea Environment Institute, 2007), http://library.me.go.kr/DLiWeb25/comp/search/viewer.aspx?type=F&cid=176063&id=20391&url= (accessed 20 July 2010).

45. Ibid.

46. Costanza et al., note 42.

47. Incheon Development Institute, Seeing the 120 Years of Incheon through Maps (Incheon, Republic of Korea: Incheon Metropolitan City, 2004), http://www.idi.re.kr/WEBBOOK/prg/skin01/ebook.htm?C060323002.xml&pagenum=0 (accessed 10 July 2010).

48. Songdo IBD, note 6.

49. LEED (Leadership in Energy and Environmental Design) is “an internationally recognized green building certification system, providing third-party verification that a building or community was designed and built using strategies aimed at improving performance across all the metrics that matter most: energy savings, water efficiency, CO2 emissions reduction, improved indoor environmental quality, and stewardship of resources and sensitivity to their impacts,” developed by U.S. Green Building Council (USGBC). U.S. Green Building Council, Intro—What LEED Is, http://www.usgbc.org/DisplayPage.aspx?CMSPageID=1988 (accessed 22 July 2010).

50. U.S. Green Building Council, LEED for Neighborhood Development, http://www.usgbc.org/DisplayPage.aspx?CMSPageID=148 (accessed 22 July 2010).

51. Songdo IBD, note 6.

52. Gale International, “South Korea's Songdo International Business District Is a Winner of Inaugural Sustainable Cities Award,” press release, (New York, 16 June 2008), http://www.songdo.com/Uploads/FileManager/Gale/Press%20Releases/2008/2008.06_uli%20songdo%20award.pdf (accessed 22 July 2010).

53. Birds Korea, Large-Scale Wetland Reclamation of Song Do Tidal-Flat Approved, http://www.birdskorea.org/Habitats/Wetlands/Songdo/BK-HA-Songdo-Tidal-flat-reclamation-2009-03.shtml (accessed 12 June 2010). This page also includes the table “Species Recorded in Internationally Important Concentrations at the Song Do Tidal-flat since 2006.”

54. Incheon Development Institute, note 47.

55. Ministry of Land, Transport, and Maritime Affairs, “60.8km2 of Tidal Flats Disappeared in Last Five Years,” press release (Seoul, Republic of Korea, 4 May 2010).

56. Incheon KFEM, “Tidal Flat Loss in Incheon Is the Largest in the Nation and It Will Be More Serious in the Future,” press release (Incheon, Republic of Korea, 20 August 2009).

57. Oliver, note 15.

58. Birds Korea, Song Do Tidal-flats, http://www.birdskorea.org/Habitats/Wetlands/Songdo/BK-HA-Songdo.shtml (accessed 28 July 2010).

59. Songdo IBD, note 6.

60. After a series of protests by environmental and civic groups, Incheon decided in December 2009 to reserve 6.11 km2 (3.61 km2 in Section 11 and another 2.50 km2 in Sections 6 and 8) and approved to continue to fill the rest of the remaining tidal flats. The LEED-ND guidelines list a specific procedure when a project might affect an endangered species, and the developers did not go through that process. The area of the remnant tidal flat is not based on a scientific plan.

61. U.S. Green Building Council, LEED for Neighborhood Development Certified Pilot Projects and Plans List—Updated 01/05/11, http://www.usgbc.org/ShowFile.aspx?DocumentID=5205 (accessed 20 January 2011).

62. I. McHarg, Design with Nature, 25th ed. (New York: J. Wiley, 1994), 81.

63. M. Hough, Cities and Natural Process (London and New York: Routledge, 1995).

64. A. W. Spirn, The Granite Garden: Urban Nature and Human Design (New York: Basic Books, 1985).

65. J. Corbett and M. N. Corbett, Designing Sustainable Communities: Learning from Village Homes (Washington, DC, and Covelo, CA: Island Press, 2000).

66. J. T. Lyle, Regenerative Design for Sustainable Development (New York: John Wiley and Sons, 1996).

67. N. J Todd and J. Todd, From Eco-cities to Living Machines: Principles of Ecological Design (Berkeley, CA: North Atlantic Books, 1994).

68. S. Van der Ryn and S. Cowan, Ecological Design, 10th ed. (Washington, DC: Island Press, 2007).

69. G. M. Kondolf, “Dear Mayor Sang-Soo Ahn,” I-today, 12 August 2009), opinion, http://www.i-today.co.kr/news/articleView.html?idxno=45650 (accessed 20 July 2010).

70. Mang et al., note 44.

71. Lyle, note 66, 235.

72. Lyle, note 66, 18; Van der Ryn and Cowan, note 68, 185.

73. R.T. Hester, Design for Ecological Democracy (Cambridge, MA: MIT Press, 2006), 117.

74. D. K. Lee and B. M. Kim, “Important-Satisfaction Analysis as a Management Strategy of Suncheon Bay Ecological Park,” Journal of the Korean Institute of Landscape Architecture 37, no. 6 (2010): 39–47.

75. Ibid.

76. C. H. Koh, “Korean Megatidal Environments and Tidal Power Projects: Korean Tidal Flats—Biology, Ecology and Land Uses by Reclamations and Other Feasibilities,” La Houille Blanche, no. 3 (1997): 66–78.

77. Federal Register, Notice of Availability of the Draft Programmatic Environmental Impact Statement for Solar Energy Development in Six Southwestern States and Notice of Public Meetings, http://www.federalregister.gov/articles/2010/12/17/2010-31725/notice-of-availability-of-the-draft-programmatic-environmental-impact-statement-for-solar-energy#p-3 (accessed 13 January 2011).

78. A.Leopold, A Sand County Almanac, and Sketches Here and There (London and New York: Oxford University Press, 1989), 211.


Yekang Ko is a PhD candidate in the Department of Landscape Architecture & Environmental Planning, University of California, Berkeley.

Derek K. Schubert is an associate at John Northmore Roberts & Associates, Landscape Architecture and Land Planning, Berkeley, California.

Randolph T. Hester is an emeritus professor of the Department of Landscape Architecture & Environmental Planning and Urban Design, University of California, Berkeley. The authors acknowledge SAVE International, the students of the graduate course LA205 (Environmental Planning Studio) at the University of California at Berkeley, and Professor Jong Ho Hong and Professor Sun-Jin Yun (of the Graduate Institute of Environmental Studies at Seoul National University) for their help and comments

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