September 13, 2019
Mr. Peter ShadieDirector, IUCN World Heritage Programme
Request for a Study of the “Amami-Oshima Island, Tokunoshima Island, the northernpart of Okinawa Island and Iriomote Island” Natural World Heritage Candidate Site
We represent Japan Environmental Lawyers for Future (JELF), an environmentalorganization comprising about 450 lawyers throughout Japan. JELF is Japan’s largest
environmental organization of lawyers. In partnership with other Japaneseenvironmental organizations and academic societies concerned with the ecosystem, weare proceeding with a lawsuit to protect Katoku Beach, located in Setouchi Town ofKagoshima Prefecture, from large artificial structures. We hereby present the following
request to the IUCN.
Japan Environmental Lawyers for Future (JELF) Headquarters
2nd Floor, Akita Gakuenmeieki Building
15-19 Tsubaki-cho, Nakamura-ku, Nagoya, Japan 453-0015
Telephone: 052-459-1753
Email: jelf@green-justice.com
Executive Director: Naoki Ikeda, Lawyer
Coordinator: Haruki Nishioka, Lawyer

I. Summary
Preparations are currently being made for the the construction of a seawall
construction on the Katoku Coast1 in Kagoshima Prefecture. This will result in the lossof the valuable natural resources of this location.
The Katoku Coast is a beautiful natural coast. Little such coast remains in AmamiOshima. The Katoku River empties into the sea at Katoku Beach, and its watershed
hosts a diverse ecosystem endemic to the island. Katoku River, Katoku Beach, and their
periphery form a continuous region with the proposed “Amami-Oshima Island,
Tokunoshima Island, the northern part of Okinawa Island and Iriomote Island” site,which the Japanese government wants inscribed on the World Heritage List. Katoku
Coast should be conserved along with the government-proposed site.
As such, we believe that keeping Katoku Coast in its natural state is essential for
judging the requirements for “integrity” needed for World Heritage inscription.
Additionally, the Katoku Coast and Katoku River watershed still host the unique
Amami ecosystem, which should be designated part of the proposed site. It should,therefore, have been designated thus from the outset, but the Japanese government has
not even designated it a buffer zone. Arguably, the Japanese government has incorrectly
assessed the value of Katoku Beach and also the natural value of Amami Oshima, andtherefore the government’s proposal does not fulfill the “protection and management”
requirement for World Heritage List inscription.
For this reason, on the occasion of the field study scheduled for this summer, we ask
1* The coast at Katoku, in Setouchi Town, Oshima County, Kagoshima Prefecture.

_Katoku is in the southern part of Amami Oshima.

-1-

that the IUCN start by investigating the state of the Katoku Coast. We also strongly
request that, because seawall construction on said coast would damage its naturalenvironment and ecosystem, the IUCN issue a recommendation for corrective action toJapan’s government so that it would cancel construction.
II. The Katoku River Area and Katoku Beach Have Outstanding Universal Value
The Katoku Beach has a form called a pocket beach. It has a natural sandy beachwith no artificial structures, which is unusual even in the Ryukyu Archipelago.
Although much of the Amami Oshima coast is made of sand with biological origins,such as that from coral, Katoku Beach’s sand is non-coral river sand transported thereby the Katoku River, which is a rarity on this island. Beginning in the Ryukyu Kingdomera, people in the Okinawa-Amami region practiced a traditional way of coastal
protection which involved conserving sandy beaches by planting kewda (Pandanusodorifer) trees. Along with this kewda forest, Katoku Beach in its entirety presents abeautiful landscape. Via the Katoku River, the beach forms a continuum with theupstream forested area, so that a nearly untouched and integrated natural environment
and ecosystem stretch from the mountains to the sea via the river.
Owing to a long history of repeated division and isolation as a continental island, theKatoku Coast and Katoku River watershed have rich biodiversity featuring many
endemic species, endangered species, and more, thus presenting a natural environment
which should be conserved as an integral part of the proposed site. For example, thegreen sea turtle (Chelonia mydas) and loggerhead sea turtle (Caretta caretta)*2 comeashore here to lay their eggs. In 2002 the leatherback turtle (Dermochelys coriacea),*3
an endangered species, was seen coming ashore to lay eggs. In addition, hermit crabsincluding a terrestrial hermit crab (Coenobita sp.) and six endangered shellfish species
have been observed here, which indicates that land-sea continuity is maintained. What ismore, the Katoku River provides habitat for the endangered Ryukyu ayu (P. altivelis
ryukyuensis), which has already disappeared from Okinawa and is now found only on
Amami Oshima. This fish swims upriver into the mountains to spawn, thereby creating
integrated mountain-river continuity.
As this shows, the Katoku Coast is a priceless natural coast which provides habitatfor many endangered species; features continuity and integration of mountains, a river,and the sea; and has an untouched sandy beach without a seawall.
Seawall construction is also strongly opposed by prominent Japanese environmentalorganizations and activists including the Nature Conservation Society of Japan (NACSJ), Japanese Association of Benthology, The Ecological Society of Japan, The
Ichthyological Society of Japan, Association for Protection of Marine Communities,
Save Amami, Society for Protecting Amami’s Forests, Rivers, and Coastal ecosystems,
Amami Nature Conservation Association, Miyuki Okuda, Satoko Seino, as well as
28,000 signatories of the change.org.petition pleading for the preservation of the"Jurassic Beach" of Amami and against a humongous seawell.
III. Requirements for World Heritage List Inscription
To be inscribed on the World Heritage List, it is necessary for the World Heritage
Committee to find “outstanding universal value.” Amami Oshima’s geographical,
ecological, and cultural value have “outstanding universal value” that is suitable for the22*2 Endangered A2bd (IUCN), Endangered II (Japan Ministry of Environment).

_33*3 Vulnerable A2b (IUCN).

_-2-heritage of humanity. Inscription on the list also necessitates fulfillment of therequirements for the site’s “integrity” and a “protection and management mechanism,”
but destruction of the Katoku Coast would clearly prevent fulfillment of therequirements for integrity and a protection and management mechanism, which areneeded for inscription of the proposed site.
III-1. Integrity“Integrity” means that a site still has all of what shows its outstanding universal
value for World Heritage. As stated above, the Katoku Coast and Katoku River
watershed form a mountain-river-sea continuum, and even now host a diverse
ecosystem which is peculiar to Amami Oshima and which corresponds to thesecontinuously linked geographical characteristics. There are also initiatives at Katoku
Beach and the Katoku River watershed to learn from and enjoy Amami Oshima’s
natural environment. And in relation to the World Heritage purpose of cultural tourism,
the Katoku River watershed, the sea, and montane area are an integrated whole thatshapes a culture.
A very small part of the Katoku River’s upstream portion has been designated a
proposed site by the government, but we argue that in order to satisfy the requirement
for integrity, the Katoku River area and Katoku Coast must also be placed within theproposed natural heritage site.
That is to say, as long as the Katoku River area and Katoku Beach are not includedin the proposed natural heritage site, that site would arguably lack integrity andcontinuity, and would thus be inadequate in terms of the integrity requirement.
Although the government has included a small part of the Katoku River headwater area
in its proposed site, it has not proposed Katoku Beach and the entire Katoku River areaeven as a buffer zone. Further, permitting the construction of a large structure at Katoku
Beach would physically damage the heritage and mar the cultural value of AmamiOshima.
III-2. Protection and Management Mechanism
Inscription as World Heritage requires Japan to have a domestic legal system and aprotection and management mechanism for implementing the World Heritage
Convention. In the protection and management of a World Heritage site, its outstanding
universal value and its state of integrity must be maintained and reinforced. In order toproperly conserve humanity’s assets, it is necessary to enact domestic laws fordesignated sites, and in addition to establish not only designated sites but also
appropriate buffer zones, thereby protecting designated sites from recklessdevelopment.
However, although the Japanese government and Kagoshima Prefecture recommend
Amami Oshima as a natural World Heritage site, they not only exclude the Katoku
Coast and Katoku River watershed from the designated site, but also exclude them fromthe buffer zone, and pursue seawall construction into the bargain. If the government
designated Katoku Beach a buffer zone and properly protected it under the NaturalParks Law or other domestic law, such a seawall would not be built.
That the Katoku Coast and Katoku River watershed have, for the sake of seawall
construction, not been designated even as a buffer zone happened because thegovernment erroneously assessed the natural value of Katoku Beach and even of
Amami Oshima itself. With an inadequate conservation and management system, andfurther with the coast and watershed being excluded from the buffer zone, it is safe to
say that the government’s stance is not one of sincerely implementing protection policy.

-3-If seawall construction proceeds as at present and a concrete seawall is built, it willclearly have an irreversible impact on the valuable natural environment of the Katoku
River coast, with the consequence being the loss of the valuable Katoku Coast asset.
Therefore, unless the Japanese government and Kagoshima Prefecture immediately
cancel the Katoku Coast seawall construction plan and stop construction work, and at
the least designate the Katoku River area and Katoku Beach a buffer zone, arguably therequirement for a protection and management mechanism will not be satisfied, and theproposed site should not be inscribed as a World Heritage site.
IV. Conclusion
In view of this situation, we hope that the IUCN will, in its field study scheduled forOctober 2019, properly ascertain the well-preserved natural state of the Katoku Coast.
Additionally, we strongly request that, having fully understood the gravity of thesituation that would result if seawall construction on the Katoku Coast destroys theirreplaceable natural environment and ecosystem of Katoku Beach, the IUCN advises
the Japanese government to change its plan and cancel seawall construction.

-4-