政策倡議及咨詢

BY EMAIL ONLY
24
 
March
 
2025

Dr. CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)

cc.
Dear Dr. Chui,
Green Power’s comments on the Project Profile for South-East Asia Hainan-Hong Kong Express (SEA-H2X) Submarine Cable System
Green Power’s comments on the Project Profile for South-East Asia Hainan-Hong Kong Express (SEA-H2X) Submarine Cable System

Green Power would like to draw your kind attention to our concerns regarding the above-captioned Project Profile (PP).  

1. Coral Communities  

Although the Project Profile mentions that the proposed cable route avoids known coral communities, we are concerned about the potential indirect impacts on these sensitive marine habitats. The suspended solids generated during the cable laying process could travel up to 180 meters in a worst-case scenario (Section A4.1.3.2). Given that corals are highly sensitive to sedimentation, we recommend the use of silt curtains during the cable burial and repair works to minimize the spread of suspended solids.  

2. Cetaceans

As number of dolphins stranding cases is extraordinarily high locally in 2025, avoidance measures should be taken additionally. Use the vessels, machines, tools, equipment, installations which will accidentally trap, entangle or hurt cetaceans, especially Chinese White Dolphins and Finless Porpoises, should be avoided.

3. Waste Management

We appreciate the proponent’s commitment to proper waste management, including the disposal of debris collected during the route clearance and cable laying process. However, we recommend the installation of surveillance systems on vessels to monitor and prevent any illegal dumping at sea. This would ensure that all waste and by-products, such as old cables and debris, are properly stored, transported, and disposed of at designated facilities.  

4. Water Quality Monitoring

While the proponent outlines a water quality monitoring plan, we recommend that the monitoring frequency and parameters be expanded to ensure comprehensive coverage of potential impacts. Specifically, we suggest that monitoring be conducted more frequently during the initial stages of cable laying and that additional parameters, such as nutrient levels, be included to assess the potential for eutrophication in sensitive areas.  

5. Cumulative Impacts

The Project Profile mentions that the SEA-H2X cable system will be installed concurrently with other submarine cable projects, such as the Hong Kong – Guam Submarine Cable Project (HK-G) and the Sihanoukville – Hong Kong (SHV-HK) Submarine Cable System. We are concerned about the potential cumulative impacts of these projects on marine ecology, particularly in areas where multiple cables cross or are laid in close proximity. We recommend a more detailed assessment of cumulative impacts, including the potential for increased sedimentation and disturbance to marine habitats.  

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).

Green Power would like to draw your kind attention to our concerns regarding the above-captioned Project Profile (PP).  

1. Coral Communities  

Although the Project Profile mentions that the proposed cable route avoids known coral communities, we are concerned about the potential indirect impacts on these sensitive marine habitats. The suspended solids generated during the cable laying process could travel up to 180 meters in a worst-case scenario (Section A4.1.3.2). Given that corals are highly sensitive to sedimentation, we recommend the use of silt curtains during the cable burial and repair works to minimize the spread of suspended solids.  

2. Cetaceans

As number of dolphins stranding cases is extraordinarily high locally in 2025, avoidance measures should be taken additionally. Use the vessels, machines, tools, equipment, installations which will accidentally trap, entangle or hurt cetaceans, especially Chinese White Dolphins and Finless Porpoises, should be avoided.

3. Waste Management

We appreciate the proponent’s commitment to proper waste management, including the disposal of debris collected during the route clearance and cable laying process. However, we recommend the installation of surveillance systems on vessels to monitor and prevent any illegal dumping at sea. This would ensure that all waste and by-products, such as old cables and debris, are properly stored, transported, and disposed of at designated facilities.  

4. Water Quality Monitoring

While the proponent outlines a water quality monitoring plan, we recommend that the monitoring frequency and parameters be expanded to ensure comprehensive coverage of potential impacts. Specifically, we suggest that monitoring be conducted more frequently during the initial stages of cable laying and that additional parameters, such as nutrient levels, be included to assess the potential for eutrophication in sensitive areas.  

5. Cumulative Impacts

The Project Profile mentions that the SEA-H2X cable system will be installed concurrently with other submarine cable projects, such as the Hong Kong – Guam Submarine Cable Project (HK-G) and the Sihanoukville – Hong Kong (SHV-HK) Submarine Cable System. We are concerned about the potential cumulative impacts of these projects on marine ecology, particularly in areas where multiple cables cross or are laid in close proximity. We recommend a more detailed assessment of cumulative impacts, including the potential for increased sedimentation and disturbance to marine habitats.  

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).

Yours faithfully,

LUI Tak Hang, Henry
Senior Conservation Manager
Green Power

Yours faithfully,

LUI Tak Hang, Henry
Senior Conservation Manager
Green Power

二零二五年
三月
二十四日