In Guangzhou, the “Shenhai to Haikou Expressway Huocun to Longshan Section Expansion Project” (hereinafter referred to as “this project” or “Shenhai Expressway Project”) is under heated construction with a total investment of 15.7 billion yuan. On August 11, 2023, we suddenly searched for the environmental impact assessment report and found that fireflies, an environmental indicator species, were completely overlooked, and there was also vague information about the national second-class protected plant, the Golden Hair Dog Fern. The deadline for public disclosure is August 14, making it a critical moment. Fireflies cannot speak, and Guangzhou’s extremely rare habitat that gathers 10 species of fireflies needs your voice. (Ways to participate are listed at the end: ‘Fireflies are silent, but we can speak up.
1.A Tiny Place Gleaming with Fireflies
If we wait until autumn, we might see the fireflies dancing in the air…
In May and June in Guangzhou, right next to the North Second Ring Expressway, in the wilderness of Muyuan Village, hundreds of fireflies flicker with tranquil light at night.
During the peak breeding season for most fireflies, enthusiasts found that in addition to the Yellow Broad-edge Firefly and Lei’s Firefly listed in the “National Protection List of Terrestrial Wild Animals with Important Ecological, Scientific, and Social Value”, there are also Pseudo-patterned Fireflies and Yellow-headed Veined Fireflies, as well as Orange Fireflies, Female Light Fireflies, Brown-rimmed Black-end Fireflies, Gold-rimmed Window Fireflies, Crescent Moon Window Fireflies, and the Full-body Luminescent Worm still under investigation, totaling 10 species.
The Firefly Distribution Map That’s About to Disappear
Their secret habitat includes ponds, bamboo forests, wild grasslands, and Golden Hair Dog Dells… Although the noise and light from the expressway disrupt the tranquility of their home, perhaps they are also trying hard to adapt to the pace of human society’s development, continuing to thrive in this tiny place. However, this hope of concession might soon vanish.
At that time, on the other side, on the opposite side of the North Second Ring, the original wilderness and forests had been leveled, and a major project, the expansion of the Shenhai Expressway in Guangzhou, was underway. According to the construction plans, this section (from Changping Interchange to Badou Interchange) is expanding from six lanes to twelve lanes. The park across the street had already been covered by the project, and we cannot trace back to its original appearance and the creatures there.
As invertebrates, animals like fireflies are often not considered in environmental assessments. But the tiny fireflies, besides being shrouded in a mysterious veil of beauty, are extremely important for biodiversity. Moreover, because they have high environmental quality requirements for air, water, soil, and vegetation, fireflies are also a kind of ecological indicator species.
2. If the Ponds, Bamboo Forests, and Mountains Disappear
Will the Fireflies Still Be There?
Just this May and June, we found 10 species of fireflies in this area. They coexist harmoniously with their surrounding environment. The water in the ponds nurtures Lei’s Fireflies. If their habitat disappears, they cannot migrate to find new homes. For terrestrial fireflies, the humid air environment created by ponds is also crucial.的
Next to the pond, the tall bamboo shields the nearby bright lights, providing a cool shelter for the larvae of Orange Fireflies and Crescent Moon Window Fireflies, making the pond a paradise for Lei’s Fireflies.
Orange Firefly Larva Hunting Earthworms Under the Bamboo Forest
Near the entrance of Tianlu Lake Tunnel, the bushes and ferns on both sides of the forest are paradise for Pseudo-patterned Fireflies, Orange Fireflies, and Yellow-headed Veined Fireflies. This forested area, located within the Guangzhou Tianlu Lake Forest Nature Park (within the ecological protection red line, where development and production activities are strictly prohibited), is the back mountain of Muyuan Village and also its Feng Shui forest. The ancestors established Feng Shui forests, hoping to bring good fortune to the residents.
Based on this, the Feng Shui forest has preserved a rich biodiversity. The forest’s South Asian subtropical evergreen broadleaf vegetation community is abundant in species and features a complex community structure, serving as a green shield for Muyuan Village.
Near the Tianlu Lake Tunnel entrance, there’s also a population of about 2000 square meters of the nationally protected plant Golden Hair Dog (approximately 350 to 440 plants), a number that is quite rare today.
Golden Chicken Fern（Cibotium barometz）
It’s also here, under the canopy of black fruit calamus, that we see the brightest orange glow in the night.
During the heatwaves and torrential rains of June, we were also thrilled to discover glowing leaves, branches, twigs, and soil in this Feng Shui forest. It turns out that bioluminescent fungi were feasting on rotting leaves and wood. Their miraculous existence is owed to the protection offered by black fruit calamus, Schima, Clerodendrum trichotomum, ferns, mosses, and lichens.
Now, Muyuan Village is in the process of being demolished. The elders who have moved away occasionally return to tend their gardens, but the sacred land that once blessed Muyuan Village is trembling amidst the brisk pace of construction.
According to the project plan, the expansion area of the North Second Ring in Guangzhou, including tunnel, roadway, bridge construction, slope protection, drainage channels, and street lighting, will significantly alter this pure land. The widening of the tunnel entrance will inevitably encroach upon the Feng Shui forest area.
3. Four Major Doubts in the Environmental Assessment
Is the Conservation of Fireflies Not Considered?
After reading the environmental impact assessment report for “Shenyang to Haikou National Expressway Huocun to Longshan Section Expansion Project,” we gained the following information, along with some questions.
According to the project plan, the expansion area of the North Second Ring includes the construction of tunnels, roadways, bridges, slope protection, drainage channels, etc. And according to the construction drawings, this section (from Changping Interchange to Badou Interchange) is expanding from six lanes to twelve lanes, which will significantly change the natural environment of this area.
Question 1: The reason for the expressway expansion project crossing the ecological red line of Tianlu Lake Forest Park is not sufficient.
Guangdong Tianlu Lake Forest Park and Guangzhou Huolu Mountain Forest Park are within the ecological red line, where development and production activities are strictly prohibited, except for limited human activities that do not damage ecological functions, under the premise of compliance with current laws and regulations, except for national major strategic projects. However, the project’s environmental assessment does not explain what constitutes a national major strategic project, and its crossing of the ecological protection red line of Guangdong Tianlu Lake Forest Park does not belong to limited human activities that do not damage ecological functions.
According to Article 17 of the “Guangdong Province Forest Park Management Regulations,” construction projects that destroy forest resources and landscapes, hinder tourism, or pollute the environment are not allowed within forest parks.
From the environmental assessment document, we learned that the project party adjusted the operational range of Tianlu Lake Forest Park to avoid the ecological red line and forest park range to ensure the legality of the expressway expansion project, and it has passed the expert review meeting. However, the approval process is still ongoing. Therefore, the project evaluation scope involves encroachment on Guangdong Tianlu Lake Forest Park, and all discussions and illustrations about “being near” Guangdong Tianlu Lake Forest Park in the environmental assessment are still hypothetical.
Question 2: There’s no clear conservation plan for the large population of Golden Hair Dogs affected by the project in the environmental assessment. Also, the specific number of the population is not mentioned.
The environmental assessment descriptions of the Golden Hair Dog fern are mostly “2 types of second-class wild plants in the area,” with specific numbers for other trees but not for the Golden Chicken Fern.
(Screenshot from the environmental assessment for this project)
In the environmental assessment for phase one of this project (opposite the Firefly Park), there are records of the number of Golden Chicken Fern in the same area. At that time, the scope of the preliminary project did not pass through the Feng Shui forest with the Golden Hair Dog population, and there was a count for the Golden Chicken Fern population; it’s unclear why this environmental assessment, which explicitly encroaches on theGolden Chicken Fern population, did not mention it.
(Screenshot from the environmental assessment of the preliminary project for the Shenhai Expressway Huocun to Longshan section)
Golden Chicken Fern（Cibotium barometz）, a plant species that has survived since the Jurassic period, is mainly protected at the national level due to its weak root system and slow growth. It’s extremely challenging to relocate such a large population of Golden Chicken Fern.
How exactly to relocate? Where to? How to ensure the survival rate of relocated protections? Who will supervise? Unknown……
Question 3: This environmental impact assessment report overlooked the ten cherished species of fireflies living in this area (from Chang ping Interchange to Badou Interchange).
As important ecological indicator species, fireflies play a crucial role in the biodiversity, water quality, and environmental health of the area. The maintenance and continuation of their populations have always been important subjects of ecological research. With human activities and environmental development, fireflies’ habitats are severely compressed, and nighttime artificial light pollution, pollution, and pesticide runoff have significantly reduced the number of fireflies over the past decades. To protect this highly valuable species and their habitats, a detailed survey and study should be conducted again, listing their species (including those not discovered by volunteers), the project’s impact on them, and ecological compensation measures.
For example, species reliant on this piece of land for survival, such as Pseudo-patterned Fireflies, Yellow-headed Veined Fireflies, unknown Female Light Fireflies, and suspected species of Hanging Mustache Fireflies, remain a mystery in terms of their life habits. It’s currently impossible to achieve artificial breeding and habitat creation for these species on a global scale. The unknown Female Light Fireflies and suspected new species of Hanging Mustache Fireflies, possibly new and rare, hold immeasurable research and ecological value. If construction proceeds recklessly, it may lead to the extinction of these species.
Question 4: How is the protection of Feng Shui forests emphasized in the preliminary construction project reflected in this environmental assessment?
In the environmental impact assessment report for the “Shenyang to Haikou National Expressway Huocun to Longshan Section Expansion Project Tianlu Garden Tunnel to Badou Interchange Preliminary Project” (i.e., the major preliminary project for this construction), it was mentioned that this Feng Shui forest should be protected, but we couldn’t find relevant information in this environmental assessment.
In the South, forests or woodland are arranged according to Feng Shui principles to influence people’s fortunes and well-being through interaction with the environment and natural elements, a tradition that has lasted for thousands of years. This Feng Shui forest has retained rich biodiversity, with a complex community structure of South Asian tropical evergreen broad-leaved forest vegetation, acting as a green barrier for Muyuan Village. This place is also the core habitat for four known species of fireflies.
Feng Shui Forest
The preliminary construction only approached the Feng Shui forest, while the overall construction’s environmental assessment for the Tianlu Lake Tunnel expansion will occupy the Feng Shui forest. How do the contents of the two environmental assessments for the same project interconnect and comply with each other?
As the project begins, the destruction of habitats will spell disaster for the fireflies. What can we do now? Are there better solutions?
4.Firefly Relocation？Conservation？
Almost Impossible
1.The breeding period for fireflies, when they are seen flying, lasts about a week, while for the rest of the time (half a year to a year), they are in the larval stage, crawling on the ground without wings. Lei’s Firefly larvae, living next to the expressway in ponds, cannot fly away like birds when excavators come.
I discovered the aquatic firefly—Aquatica leii
These fireflies are highly dependent on their particular habitats, and they are not capable to escape when their habitats is being destroyed. Most of the time (half a year to a year), they are in the larval stage, with very limited mobility. The aquatic species, Luciola leii, adults of which only fly for about a week for mating, and remain as larvae, living only in the ponds. Among the firefly species we found, adult females of the unknown Rhagophthalmus sp., Pyrocoelia analis, Pyrocoelia lunata, Diaphanes sp. and the unknown species, are all wingless. As the female lays the eggs and thus contributes to the following generation, such lack of mobility restricts them to the one area. Destroying their habitat would destroy their subpopulations in the area.
For these ten species of fireflies that are highly dependent on habitat and difficult to move away, how can they be preserved in this large scale expressway expansion project? The construction work would cause irreparable ecological losses.
Unknown Rhagophthalmus sp/Photographed in “The Vanishing Firefly Park That’s About to Disappear” next to construction waste.
We provide some references on the contradiction between protecting fireflies and construction works:
(1) The Japanese Government gave up building railways in order to protect fireflies, and through the joint efforts of local governments, scientific research institutions and private groups, many firefly watching locations were established which attract large numbers of tourists every years;
(2)XinXian Trail (a firefly habitat) in New Taipei City was paved with cement or asphalt during the renovation project after typhoon damage, and this activity was questioned as a threat to the fireflies. Finally, the construction plan was integrated with firefly protection elements.
For these several species of fireflies, which are highly dependent on their habitat and have weak flight capabilities, it’s difficult to protect them through relocation. How will they be preserved amidst this massive construction project? Currently, the firefly population resources are completely ignored by construction projects. If construction proceeds hastily, it will cause irreparable ecological damage to Guangzhou’s firefly resources.
If these small lives, fragile as ants, are insignificant in the face of major projects, then what will they, elsewhere, have to give way to next time?
We believe these are directions that “The Firefly Park That’s About to Disappear” can refer to. Could the project developers, upper-level departments, and we explore friendly designs together, to preserve “The Firefly Park That’s About to Disappear”? For instance, by not expanding the tunnel and preserving the Feng Shui forest.
We hope that in the era of striving to build an ecological civilization across the country, the advancement of this project will include perspectives and voices from multiple parties, participating together to ensure convenience benefits humans while also benefiting other lives sharing this region.
Fireflies Can’t Speak, But You and I Can, Your voice is very important; fireflies need your vote to participate —
The environmental impact assessment report for the Shenyang to Haikou National Expressway Huocun to Longshan Section Expansion Project is open for public comment until August 14, 2023. We hope you can join us in expressing our opinions —
According to the “People’s Republic of China Environmental Impact Assessment Law” and “Construction Project Environmental Impact Assessment Public Participation Mechanism,” the environmental impact assessment report for the Shenyang to Haikou National Expressway Huocun to Longshan Section Expansion Project is made public before approval to ensure the public’s right to know, participate, and supervise the environmental impact of construction projects.
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Phone: 020-83203175/020-32615834/
Email: 1048428542@qq.com
The environmental impact assessment report link: https://pan.baidu.com/s/11lc_B38MaI_u_FXDIEvCtQAccess code: 1234
Public opinion form for construction project environmental impact assessment link: https://pan.baidu.com/s/1LlypSI9dXRVjS1JUr7893QAccess code: 1234
Content reference:
1.The environmental impact assessment report ignored the existence of ten precious species of fireflies living in this area (from Changping Interchange to Badou Interchange). As important ecological indicator species, fireflies have a significant effect on the area’s biodiversity, water quality, and environmental health. Their population maintenance and continuation have always been crucial topics of ecological research. With human activities and environmental development leading to severe habitat compression, nighttime artificial light pollution, plus pollution and pesticide runoff, the number of fireflies has sharply declined in recent decades. To protect this highly valuable biological and its habitat, a detailed re-examination and study should be conducted, listing their species (including those not found by volunteers), the project’s impact on them, and ecological compensation measures.
2.The expressway expansion project’s justification for crossing the ecological red line is insufficient. Guangdong Tianlu Lake Forest Park and Guangzhou Huolu Mountain Forest Park are within the ecological red line, where development and production activities are strictly prohibited under current legal regulations, except for limited human activities that do not harm ecological functions, other than national major strategic projects. However, the project’s environmental assessment does not explain what constitutes a national major strategic project, and its crossing of the ecological protection red line of Guangdong Tianlu Lake Forest Park does not belong to activities that do not harm ecological functions.
3.The expressway expansion project’s occupation of the Guangdong Tianlu Lake Forest Park area violates the “Guangdong Province Forest Park Management Regulations.” According to Article 17 of these regulations, construction projects that destroy forest resources and landscapes, hinder tourism, or pollute the environment are not permitted within forest parks.
4.From the environmental assessment document, we learned that the project party has adjusted the operation scope of Tianlu Lake Forest Park to avoid the ecological red line and the forest park range, ensuring the expressway expansion project’s legality. It has passed an expert review meeting, but the approval process is still in progress. Therefore, the evaluation scope of the project involves encroaching on Guangdong Tianlu Lake Forest Park, and all statements and illustrations regarding “proximity” to Guangdong Tianlu Lake Forest Park in the environmental assessment are still hypothetical.
5.The environmental assessment report’s statement on page 64, section 2.3, about the ecological protection objectives, “This project is an expansion project, and the route is located in the Huangpu and Baiyun districts of Guangzhou, where the level of urbanization is high, and the overall ecological sensitivity is generally low,” is incorrect.
6.Although the project route has a high level of urbanization, the overall ecological sensitivity is not “low.” Just a two-month survey within a corner of Guangdong Tianlu Lake Provincial Forest Park (inside “The Firefly Park That’s About to Disappear”) found that there are as many as 10 species of fireflies, indicating that the ecological sensitivity of the route needs to be re-evaluated.
7.The environmental assessment’s statement on page 137 that “Human activities are frequent along the route, and the wildlife on both sides of the existing highway are mostly species that adapt well to human disturbance. Due to their high adaptability to artificial habitats and strong mobility, as well as their wide distribution along the project route and nearby areas, with large population numbers, the species affected by the project can easily find similar habitats in nearby areas, thus, this expansion has a limited impact on the biological resources within the evaluation scope” does not establish a valid causal relationship. The environmental assessment does not provide evidence to support the statements that “Human activities are frequent along the route,” and that “due to their high adaptability to artificial habitats and strong mobility, with large population numbers,” which makes the conclusion that the expansion has a limited impact on the biological resources within the evaluation scope unsupported.
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