10 Fisheries Impact

10.1 Introduction

10.1.1.1 This section presents the baseline conditions for fisheries in the assessment area and long-term impacts on fisheries during the construction and operation phases of the Project, which has been conducted in accordance with the requirements stated in Clause 3.4.11 and Appendix I of the EIA Study Brief (No. ESB-319/2019). Potential direct, indirect, cumulative and residual impacts on fisheries resources during construction and operation phases of the Project were identified and evaluated. Mitigation measures have been recommended where necessary, and residual impacts assessed.

10.2 Environmental Legislations, Standards and Guidelines

10.2.1.1 This fisheries impact assessment was conducted according to criteria and guidelines set out in the Annex 9 and Annex 17 of the EIAO-TM in order to provide complete and objective identification, prediction and evaluation of potential fisheries impacts arising from the Project. EIAO-TM Annex 17 sets out the methodology for assessment of fisheries impacts and Annex 9 provides the evaluation criteria.

10.2.1.2 Other local legislation relevant to the fisheries impact assessment include:

· Fisheries Protection Ordinance (Cap. 171) – promotes the conservation of fish and other forms of aquatic life within Hong Kong waters by regulating fishing practices to prevent detrimental activities to the fisheries industry. The authority may also make rules for the management and control of fishing in any fisheries protection area, including but not limited to the specification of any zone within any fisheries protection area and the prohibition of any fishing in the specified zone.

· Marine Fish Culture Ordinance (Cap. 353) – regulates and protects marine fish cultured by designating areas of fish culture zone, granting licenses, prohibiting unauthorised vessels and any deposition of chemicals or other substances which are likely to cause injury to fish in a fish culture zone.

· Water Pollution Control Ordinance (Cap. 358) – aims to control water pollution in waters of Hong Kong. Water Control Zones (WCZs) are designated with individual water quality objectives to promote the conservation and best use of those waters in the public interest. The most updated water quality objectives for the Junk Bay WCZ, Eastern Buffer WCZ and Victoria Harbour WCZ were revised in June 1997.

· EIAO-TM – Annex 17 sets out the methodology for assessment of fisheries impacts, in order to provide objective identification, prediction and evaluation of potential fisheries impacts arising from the Project. Annex 9 provides evaluation criteria.

10.3 Assessment Methodology

10.3.1 Assessment Area

10.3.1.1 According to Clause 3.4.11.2 of the EIA Study Brief, the assessment area for fisheries impact assessment is the same as the water quality impact assessment area (i.e. 500 m from the boundary of the Project), covering any other areas likely to be impacted by the Project. This includes areas within 500 m from the boundary of the Project, Shing Mun River Main Channel, Tolo harbour and Channel WCZs as designated under the Water Pollution Control Ordinance. Special attention was given to Yim Tin Tsai Fish Culture Zone, Yim Tin Tsai (East) Fish Culture Zone, Lo Fu Wat Fish Culture Zone and Yung Shue Au Fish Culture Zone (Figure 10.1 refers).

10.3.2 Assessment Approach and Methodology

10.3.2.1 Collation and desktop review of available relevant fisheries baseline data (e.g. AFCD Port Survey 2016/2017, EIAs and other available relevant studies) within or in vicinity to the assessment area were conducted.

10.3.2.2 Potential direct/indirect, short-term/long-term fisheries impacts arising from the Project were identified and evaluated where possible in the EIA report. Mitigation measures, monitoring and audit programme were recommended, where necessary. Special attention was given to Yim Tin Tsai Fish Culture Zone, Yim Tin Tsai (East) Fish Culture Zone, Lo Fu Wat Fish Culture Zone and Yung Shue Au Fish Culture Zone.

10.3.2.3 The criteria and guidelines as stated in Annexes 9 and 17 of the EIAO-TM were followed in the EIA report for evaluating and assessing fisheries impact arising from the construction and operation of the Project.

10.4 Baseline Conditions

10.4.1 Literature Review

10.4.1.1 Relevant literature on capture and culture fisheries within the assessment area used in the impact assessment are listed in Table 10.1 below.

Table 10.1 Baseline Information of Fisheries Resources in the Assessment Area

Relevant Literature Describing Fisheries Baseline Information in the Assessment Area

· AFCD Port Survey 2016/2017 (AFCD, 2018a)

· Aquaculture and Capture Fisheries data available from AFCD website and Hong Kong Year Book reports (AFCD, 2020a and 2020b; HKYB, 2011-2019)

· AFCD Annual Report 2017 – 2019 (AFCD, 2017; 2018b; 2019)

· Report on Survey of Fisheries Resources in Hong Kong (2010 – 2015) (AFCD, 2020c)

· Fisheries Resources and Fishing Operations in Hong Kong Waters (ERM, 1998)

· EIA report of Sha Tin Cavern Sewage Treatment Works (DSD, 2016)

10.4.1.2 The relevant desktop information reviewed is considered sufficient for evaluating the importance of potentially impacted fisheries within the assessment area. Therefore, no information gap on fisheries baseline conditions within the assessment area was identified and fisheries surveys are not required for the EIA study.

10.4.2 Sites of Fisheries Importance

10.4.2.1 There are four mariculture areas identified in the assessment area, Lo Fu Wat Fish Culture Zone (FCZ), Yung Shue Au FCZ, Yim Tin Tsai FCZ and Yim Tin Tsai (East) FCZ, which are located approximately 11.5 km, 9.1 km, 7.3 and 7.6 km away from the Project site. The locations of the key fisheries resources within the assessment area are shown in Figure 10.1.

10.4.3 Capture Fisheries

10.4.3.1 In 2020, Hong Kong’s capture fisheries’ fishing fleet comprised about 5040 fishing vessels, operated by approximately 10,150 local fishermen. In terms of production in 2020, the capture fisheries industry produced an estimated 116,000 tonnes of fisheries valued at about $2.7 billion (AFCD, 2020b). Fishing activities in the waters of Hong Kong are mainly conducted by sampans using multiple fishing gears as well as other smaller non-trawler vessels, such as gill netters, long liners, purse seiners. Trawlers and other larger non-trawlers are generally operating in the adjacent waters of the South China Sea. Trawling landed majority of the catch in Hong Kong waters prior to 31 December 2012, after which a ban on trawling was implemented with the aim to protect marine resources and ecosystem, so that the damaged seabed and depleted marine resources can rehabilitate. Some recent data on local capture fisheries industry are summarised in Table 10.2 below.

Table 10.2 Recent Figures of Hong Kong Capture Fisheries Industry

Parameter	2011	2012	2013	2014	2015	2016	2017	2018	2019	2020
Fishing fleet size (No. of vessels)	4,030	3,990	3,980	4,540	5,050	5,160	5,150	5,050	5,030	5,040
Local Fishermen engaged in capture fisheries	8,500	8,800	8,800	9,400	10,500	10,800	10,600	10,200	10,100	10,150
Production (tonnes)	171,000	155,230	170,129	160,789	145,193	142,775	127,554	124,300	122,900	116,000
Values of production (HK$ million)	2,360	2,320	2,340	2,530	2,340	2,600	2,600	2,800	2,800	2,700
Note: 1. Sources: AFCD, 2017, 2018b, 2019, 2020b; HKYB, 2011-2019

10.4.3.2 The latest AFCD Port Survey 2016/2017 (AFCD, 2018a) provides the most updated information on capture fisheries in Hong Kong waters, including both fishing operation and fisheries production. In general, the highest fish yields in Hong Kong were obtained in the southeastern waters (e.g. Po Toi) and the southwestern waters (e.g. Cheung Chau, Soko Islands and Shek Kwu Chau). The top 10 families / groups of fish captured in Hong Kong waters were Mugilidae (mullet), Clupeidae (sardine and shad), Carangidae (scad and jack), Sparidae (seabream), Sciaenidae (croaker), Mixed squid (squid), Mixed crab (crab), Siganidae (rabbitfish), Mixed shrimp (shrimp) and Platycephalidae (flathead). According to the Report on Survey of Fisheries Resources in Hong Kong 2010 – 2015 (AFCD, 2020c), major composition of commercially important fisheries resources within the assessment area (North-eastern waters) included families of Leiognathidae, Clupeidae, Sparidae, Carangidae and Polynemidae.

10.4.3.3 The fishing operation within the assessment area was mainly conducted by sampans using multiple gears as well as smaller non-trawler vessels (AFCD, 2020b). Sampans were the dominant fishing vessels but other vessels such as gill netters, long liners and purse seiner were also operated within the assessment area. The capture fisheries data within the assessment area are summarised in Table 10.3. It is found to be similar to the Sha Tin Cavern Sewage Treatment Works (STW) EIA report, with low levels of capture fisheries particularly around Sha Tin Hoi (AFCD, 2018a).

Table 10.3 Summary of Capture Fisheries Data in the Assessment Area

Parameter

Sha Tin Hoi

Tolo Harbour

Plover Cove

Three Fathoms Cove

Tolo Channel

Overall fishing operations

(no. of vessels)

>0-50

>100-400

>50-100

>0-400

>200-600

Overall fisheries production

(kg/ha)

>0-50

>50-200

>0-50

>0-200

>200-300

Note:

1. Source: AFCD, 2018a

10.4.3.4 The number of fishing vessels operating within the assessment area was generally between >0 and 600 vessels, with very low numbers (>0 - 50 vessels) in Sha Tin Hoi, the area nearest to the Project site.

10.4.3.5 In terms of weight, >0 – 300 kg/ha fish was produced within the assessment area. The weight of fish production in Sha Tin Hoi, the area nearest to the Project site, was low (>0 – 50 kg/ha). Overall fish production increased towards the Tolo Channel, in which the fish production in Tolo Channel ranged from >200 – 300 kg/ha (AFCD, 2018a). However, this area is relatively distant (approximately 14.1 km) from the Project site.

10.4.3.6 Tolo Harbour is not considered as important spawning or nursery areas for commercial fisheries resources (ERM, 1998). Although reproductive individuals of pony fish (Leiognathus brevirostris) have been collected in Tolo Harbour, this species does not appear to have a specific spawning ground as reproductive individuals were collected in areas ranging from Tolo Harbour and northeastern waters, to Junk Bay and as far west as South Lantau (ERM, 1998). In Port Survey 2016/2017, fish fry collection was found to be negligible (AFCD, 2018a). According to the AFCD Port Survey 2006 report, low level of fish fry production (>0 – 50 tails/ha) was recorded in Tolo Harbour.

10.4.3.7 Tolo Channel has been identified as a potential fish nursery ground of Seabream species (Chrysophrys major, Rhabdosargus sarba and Sparus spp.), Shrimp (Metapenaeopsis palmensis) and Lutjanus fry (ERM, 1998). In Port Survey 2016/2017, fish fry collection was found to be negligible (AFCD, 2018a). According to the AFCD Port Survey 2006 report, fish fry production ranging from >0 – 100 tails/ha and 100 – 500 tails/ha was recorded in Tolo Channel and Three Fathoms Cove respectively. Based on the findings of the literature review, Sha Tin Hoi was not identified as an important nursery area or spawning ground (ERM, 1998).

10.4.3.8 In addition, important spawning and nursery grounds within Hong Kong waters are proposed to designate as Fisheries Protection Areas (FPAs) to protect fish fry, juvenile and spawning fish, which helps to restore fisheries resources in Hong Kong waters and promote their sustainable growth in the long run (Legco, 2013). There are two proposed FPAs in the eastern waters including “Tolo Channel and Long Harbour” and “Port Shelter”. The closest one − “Tolo Channel and Long Harbour” is located approximately over 14 km from the Project site.

10.4.4 Culture Fisheries

10.4.4.1 Mariculture areas for marine fish in Hong Kong included 26 FCZs located in various sheltered coastal areas across Hong Kong waters and occupied about 209 ha of sea area with some 925 licensed operators in 2020 (AFCD, 2020a). The majority of licensed farms are small, family-based and consisting of one to two rafts with average total area of 302 m².

10.4.4.2 There are four FCZs within the assessment area. Lo Fu Wat FCZ, Yung Shue Au FCZ, Yim Tin Tsai FCZ and Yim Tin Tsai (East) FCZ are located approximately 11.5 km, 9.1 km, 7.3 and 7.6 km away from the Project site. The locations of the FCZs are shown in Figure 10.1.

10.4.4.3 Although no figures are available for the individual production of FCZs, it was estimated that culture fisheries of marine fish production in 2020 weighed 687 tonnes and was valued at $52 million, which catered about 5 per cent of local demand for live marine fish (AFCD, 2020a). Recent figures are present in Table 10.4.

Table 10.4 Recent Figures of Hong Kong Culture Fisheries Industry

Parameter	2011	2012	2013	2014	2015	2016	2017	2018	2019	2020
Licensed operator	1,015	1,008	987	968	969	949	938	931	923	925
Production (tonnes)	1,185	1,299	1,005	1,255	1,219	1,031	1,004	850	890	687
Values of production (HK$ million)	94	117	94	115	105	86	78	71	72	52

Note:

1. Sources: AFCD, 2020b; HKYB, 2011-2019

10.4.4.4 The types of species produced from culture fisheries depend on the availability of imported fry. Common species cultured include green grouper, brown-spotted grouper, giant grouper, Russell’s snapper, mangrove snapper, goldlined seabream, and star snapper (AFCD, 2020a).

10.5 Identification and Evaluation of Environmental Impacts

10.5.1 Construction Phase

Direct Impact

No Direct Impact on Sites of Fisheries Importance

10.5.1.1 The proposed works would be confined to boundary of the Project site (existing Fo Tan Nullah and developed area alongside). There would be no loss of mariculture areas or fishing ground resulting from these works.

Indirect Impact

Construction Run-off and Land-based Construction

10.5.1.2 Wastewater generated from construction site runoff (e.g. runoff and erosion of exposed bare soil and earth, earth working area and stockpiles, etc.) as well as general land-based construction works (e.g. general cleaning and polishing, wheel washing, dust suppression, etc.) could potentially pose indirect impacts on water quality within Fo Tan Nullah (FTN), adjoining Shing Mun River Main Channel and Sha Tin Hoi. Given that the closest fishing ground (i.e. Sha Tin Hoi) and mariculture area (i.e. Yim Tin Tsai (East) FCZ) are at least 2.7 km and 7.0 km away from downstream of the Project site, together with the implementation of pollution control measures and good site practices mentioned in Section 5, no unacceptable adverse water quality impact due to the Project works is anticipated. Fisheries impacts arising from water quality deterioration due to land-based construction works are expected to be negligible.

Accidental Spillage and Potential Contamination of Surface Water

10.5.1.3 The use of chemicals such as engine oil and lubricants, and their storage as waste materials are potential sources that could affect water quality if spillage occurs and enters the adjacent water environment. Accidental spillage and potential contamination of surface water could potentially pose indirect impacts on water quality of the FTN, adjoining Shing Mun River Main Channel and Sha Tin Hoi. Given that the closest fishing ground (i.e. Sha Tin Hoi) and mariculture area [i.e. Yim Tin Tsai (East) FCZ] are at least 2.7 km and 7.0 km away from downstream of the Project site together with the implementation of pollution control measures and good site practices mentioned in Section 5, no unacceptable adverse water quality impact due to Project works is anticipated. Fisheries impacts arising from water quality deterioration due to accidental spillage and potential surface water are therefore expected to be negligible.

10.5.2 Operational Phase

Indirect Impact

No Indirect Water Quality Impacts during Normal Operation

10.5.2.1 No unacceptable water quality impact from normal operation of the Project on marine waters would be expected. As such, no unacceptable adverse impacts on mariculture areas and fishing grounds due to deterioration of water quality are anticipated.

Changes in Water Quality

10.5.2.2 With the implementation of dry weather flow intercepting (DWFI) system and engineered wetland, water quality in the nullah would be improved. Aquatic wildlife at downstream could potentially benefit from improved water quality of the nullah. Although there will be slight water quality improvement from operation of the Project, considering the small volume of treated effluent compared to nearby marine habitat, the improvement would be considered as insignificant. Together with the large distance between the Project site and marine habitats (fishing grounds and mariculture areas), the slight improvement in water quality from the Project is thus considered as insignificant.

Potential Fisheries Impacts from Maintenance Works and Desilting Works

10.5.2.1 During the operational phase, similar to the existing practices, regular maintenance works regular maintenance works for the drainage and sewerage systems along FTN, including desilting along the nullah and minor maintenance to the DWFI system installed along sections 2 (part) to 5 of FTN (Figure 2.2 refers), would be carried out by the DSD to remove excessive silts, debris and any obstructions to safeguard the hydraulic capacity of the nullah. The maintenance practices and frequency would be similar to the existing maintenance works undertaken by the DSD. It is expected that minor maintenance to DWFI system will only be undertaken on an as-needed basis and frequent maintenance (i.e. monthly) will not be required. Maintenance desilting of the nullah should be carried out on an annual basis during dry season (November to March) when the water flow is low, except during emergency situations where the accumulated silt would adversely affect the hydraulic capacity of the nullah or where flooding risk is imminent, or when complaints on environmental nuisance associated with the accumulated silt are received. These works are expected to be carried out temporarily, affecting only works area of small scale with no unacceptable impacts to water quality. With proper design of site drainage and implementation of Best Management Practices (BMPs) for stormwater discharge (detailed in Section 5), together with the large distance between the Project site and marine habitats, deterioration of water quality would be minimal and no unacceptable adverse impacts on mariculture areas and fishing grounds are anticipated.

10.6 Mitigation of Environmental Impacts

10.6.1.1 According to the guidelines in Annex 17 of EIAO-TM, general policy for alleviating fisheries impacts are in priority order of avoidance, minimisation and compensation.

10.6.2 Construction Phase

10.6.2.1 As discussed in Section 10.5.1, with the pollution control measures in place to control potential impacts on water quality (Section 5 refers), the Project is unlikely to have indirect impacts on fisheries resources (i.e. fishing ground and mariculture areas). Thus, no mitigation measures for fisheries impact are considered necessary.

10.6.3 Operational Phase

10.6.3.1 As discussed in Section 10.5.2, deterioration of water quality would be minimal and no unacceptable adverse impacts on mariculture areas and fishing grounds under normal operation of the FTN would be expected. Thus, no mitigation measures for fisheries impacts are considered necessary.

10.6.4 Overall Summary of Fisheries Impact

10.6.4.1 In accordance with the EIAO-TM Annex 9 criteria, assessment of potential fisheries impacts in the absence of mitigation within the assessment area are provided in Table 10.5.

Table 10.5 Fisheries Impact on Fishing Ground and Mariculture Areas within Assessment Area

Criteria	Fishing Ground	Mariculture Areas
Nature of impact	§ No direct loss of fishing ground and mariculture areas § No unacceptable indirect water quality impact on fisheries is anticipated
Size of affected area	Indirect Impact § The nearest fishing ground and mariculture area are more than 2.7 km and 7.0 km away from the Project site respectively. No unacceptable indirect water quality impacts on fishing ground and mariculture areas during construction and operational phases are expected
Loss of fisheries resources/production	Direct Impact § No direct loss of fisheries resources/ aquaculture and aquaculture productions during construction and operational phases Indirect Impact § The nearest fishing ground and mariculture area are more than 2.7 km and 7.0 km away from the Project site respectively. No unacceptable indirect water quality impact on fisheries resources
Destruction and disturbance of nursery and spawning grounds	No important nursery and spawning grounds of commercial fisheries species were recorded	N/A
Impact on fishing activity	Negligible	N/A
Impact on aquaculture activity	N/A	Negligible, given the large distance between Project site and aquaculture activity (>7.0 km)
Overall impact before mitigation	Negligible

10.7 Evaluation of Residual Impacts

10.7.1.1 No loss of fishing ground and mariculture areas will be result from the Project. With the implementation of pollution control measures detailed in Section 5, no unacceptable water quality impacts on fisheries (i.e. fishing ground and mariculture areas) are expected during the construction and operation phases. No unacceptable water quality impact from normal operation of the Project on marine water would be expected. Thus, no unacceptable residual impacts on fisheries resources due to water quality deterioration are anticipated.

10.8 Environmental Monitoring and Audit

10.8.1.1 As no unacceptable adverse fisheries impacts are anticipated during both construction and operational phases, no specific environmental monitoring and audit programme for fisheries impact is required.

10.8.1.2 Regular weekly site inspection during the construction phase has been proposed in Section 5 to inspect the construction activities and works area to ensure the recommended water pollution control measures are properly implemented.

10.9 Conclusion

10.9.1.1 A study based on existing information on fisheries resources and activities within the assessment area has been undertaken, following the criteria and guidelines for evaluating and assessing fisheries impact as stated in Annexes 9 and 17 of the EIAO-TM.

10.9.1.2 The Project would only involve construction works within the Project site (existing FTN and developed area alongside). No loss of fishing grounds and mariculture areas are anticipated within the assessment area. With the implementation of recommended water pollution control measures, the Project would not cause any unacceptable indirect impacts to fishing grounds and mariculture areas within the assessment area during both construction and operational phases. Thus, no further mitigation measures and environmental monitoring and audit programme are required.

10.10 References

Agriculture, Fisheries and Conservation Department (AFCD) (2017). Agriculture, Fisheries and Conservation Department Annual Report 2016-2017.

Agriculture, Fisheries and Conservation Department (AFCD) (2018a). Fisheries: Port Survey. https://www.afcd.gov.hk/english/fisheries/fish_cap/fish_cap_latest/files/common/PS201617_ENG.pdf

Agriculture, Fisheries and Conservation Department (AFCD) (2018b). Agriculture, Fisheries and Conservation Department Annual Report 2017-2018.

Agriculture, Fisheries and Conservation Department (AFCD) (2019). Agriculture, Fisheries and Conservation Department Annual Report 2018-2019.

Agriculture, Fisheries and Conservation Department (AFCD) (2020a). Fisheries: Aquaculture. https://www.afcd.gov.hk/english/fisheries/fish_aqu/fish_aqu_mpo/fish_aqu_mpo.html

Agriculture, Fisheries and Conservation Department (AFCD) (2020b). Fisheries: Capture Fisheries.https://www.afcd.gov.hk/english/fisheries/fish_cap/fish_cap_latest/fish_cap_latest.html

Agriculture, Fisheries and Conservation Department (AFCD) (2020c). Report on Survey of Fisheries Resources in Hong Kong (2010-2015). https://www.afcd.gov.hk/english/fisheries/fish_cap/fish_cap_con/fish_cap_con.html

Drainage Service Department (DSD) (2016). Sha Tin Cavern Sewage Treatment Works – EIA Report. Prepared by AECOM Asia Co Ltd. for Drainage Service Department, The Government of the Hong Kong Special Administrative Region.

Environmental Resources Management (ERM) (1998). Fisheries Resources and Fishing Operation in Hong Kong Waters. Prepared by ERM for Agriculture and Fisheries Department, HK SAR Government.

Hong Kong Baptist University (HKBU) (2011). Report on Water quality monitoring program in Shing Mun River. https://www.districtcouncils.gov.hk/archive/st_d/pdf/hec/2011/ST_HEC _2011_019_TC.pdf

Hong Kong Year Book (HKYB) (2010). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2010/en/pdf/E09.pdf

Hong Kong Year Book (HKYB) (2011). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2011/en/pdf/E09.pdf

Hong Kong Year Book (HKYB) (2012). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2012/en/pdf/E09.pdf

Hong Kong Year Book (HKYB) (2013). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2013/en/pdf/E09.pdf

Hong Kong Year Book (HKYB) (2014). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2014/en/pdf/E09.pdf

Hong Kong Year Book (HKYB) (2015). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2015/en/pdf/E09.pdf

Hong Kong Year Book (HKYB) (2016). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2016/en/pdf/E10.pdf

Hong Kong Year Book (HKYB) (2017). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2017/en/pdf/E10.pdf

Hong Kong Year Book (HKYB) (2018). Food Safety, Environmental Hygiene, Agriculture and Fisheries. https://www.yearbook.gov.hk/2018/en/pdf/E10.pdf

Legislative Council (Legco) (2013). Panel on Food Safety and Environmental Hygiene − Review of moratorium on issue of new fish culture licences. https://www.legco.gov.hk/yr12-13/english/panels/fseh/papers/fe0611cb2-1284-6-e.pdf