Dr. CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)
Green Power would like to draw your attention to our concerns and recommendations regarding the Project Profile (PP) for the Northern Metropolis Highway - San Tin Section (the Project). We have reviewed the PP and would like to highlight several critical environmental issues that need to be addressed.
1. Ecological Impacts
The Project is located in close proximity to ecologically sensitive areas, including Lam Tsuen Country Park, Wetland Conservation Area, Wetland Buffer Area, and the “Deep Bay Wetland outside Ramsar Site” Priority Site for Enhanced Conservation. The alignment of the Project may directly encroach upon and/or impose disturbance to these sensitive habitats, leading to habitat loss, fragmentation, and disturbance to wildlife. We urge the Project proponent to:
• Avoid direct encroachment on recognized and or potential sites of conservation importance and ecologically sensitive habitats.
• Conduct comprehensive ecological surveys, including year-long surveys for diverse taxa groups and habitats, with additional focus on migratory birds during their migratory seasons. Any newly identified ecologically sensitive sites should be avoided from encroaching and disturbance by the Project.
• Implement mitigation measures such as habitat reinstatement, compensation, and the provision of wildlife corridors to minimize ecological impacts. However, as the effectiveness and efficiency of mitigation measures are very limited for intact or unspoiled habitats, top priority should accord to avoidance rather than mitigation or compensation of habitat and/or ecological function loss.
• Ensure compliance with the “zero discharge policy” for Deep Bay, as any untreated surface runoff generated during construction and operation phases should be prevented from discharging into the Ngau Tam Mei Drainage Channel or its tributaries. Stormwater discharged from the Project in operation phase should be treated properly before discharging into any natural or manmade channels, e,g. Sustainable Urban Drainage System.
2. Air Quality
According to EPD’s Air Quality and health Index data, Yuen Long District, where the Project is located, is one of districts highly prone to air pollution. The Project proponent must:
• Assess cumulative air quality impacts from the Project and other nearby developments, such as the San Tin Technopole and Ngau Tam Mei.
• Formulate effective mitigation measures to control air pollution, including promotion of public transport, limiting the parking spaces of private cars, etc.
• Monitor and manage dust emissions during construction, following the measures outlined in the Air Pollution Control (Construction Dust) Regulations.
3. Waste Management
Given the rural nature of the areas adjoining the Project site, fly-tipping of solid wastes generated from the Project must be strictly controlled. We recommend:
• Strict monitoring and control of the storage, transportation, and disposal of solid wastes.
• Incorporation of mitigation measures into the works contract to prevent illegal dumping.
• Implementation of a comprehensive recycling plan to promote a zero-waste project.
• GPS tracking and instantaneous alarm systems for dump trucks entering restricted zones (e.g., Lam Tsuen Country Park, Wetland Conservation and Buffer Area, potential Wetland Conservation Parks, etc).
4. Water Quality
The Project’s alignment passes through areas connected to the Mai Po Inner Deep Bay Ramsar Site. To protect the ecology of the Ramsar Site, we propose:
• Prevention of untreated surface runoff from discharging into the Ngau Tam Mei Drainage Channel or its tributaries.
• Incorporation of a sustainable urban drainage system to treat polluted surface runoff and promote climate resilience.
• Adoption of mitigation measures to manage construction site runoff and prevent water pollution.
5. Tunnel Construction
According to Section 3.1.1, the Project will involve land-based construction works… conceptually be made up of … Construction of tunnel by both Drill & Blast (D&B). Surprisingly, its risks and potential impacts are not fully addressed in PP. No corresponding mitigation measures are proposed to reduce the impacts of
(a) blasting noise on the noise sensitive receivers;
(b) blasting vibration and no receivers vulnerable to blasting vibration are identified;
(c) blasting vibration on the geotechnical stability the nearby slopes.
Also, potential risk of blasting on Ngau Tam Mei Landfill should be assessed and location(s) of magazine has not been mentioned in PP.
6. Cultural Heritage
The Project alignment encroaches into archaeological potential areas identified in previous EIA reports. We recommend:
• Conducting a Cultural Heritage Impact Assessment to assess potential impacts on cultural heritage resources.
• Implementing mitigation measures to minimize impacts on cultural heritage, with prior agreement from the Antiquities and Monuments Office.
7. Cumulative Environmental Impacts
Given the proximity of the Project to other major developments, such as the San Tin Technopole and Northern Link, it is crucial to assess the cumulative environmental impacts. We stress the importance of including all potential environmental impacts of adjacent developments in the current EIA to avoid underestimation.
8. Public Consultation
We urge the Project proponent to arrange public consultations once sufficient information is available. This will ensure that the concerns of the local community and environmental groups are addressed.
Thank you for your attention to these matters. 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 attention to our concerns and recommendations regarding the Project Profile (PP) for the Northern Metropolis Highway - San Tin Section (the Project). We have reviewed the PP and would like to highlight several critical environmental issues that need to be addressed.
1. Ecological Impacts
The Project is located in close proximity to ecologically sensitive areas, including Lam Tsuen Country Park, Wetland Conservation Area, Wetland Buffer Area, and the “Deep Bay Wetland outside Ramsar Site” Priority Site for Enhanced Conservation. The alignment of the Project may directly encroach upon and/or impose disturbance to these sensitive habitats, leading to habitat loss, fragmentation, and disturbance to wildlife. We urge the Project proponent to:
• Avoid direct encroachment on recognized and or potential sites of conservation importance and ecologically sensitive habitats.
• Conduct comprehensive ecological surveys, including year-long surveys for diverse taxa groups and habitats, with additional focus on migratory birds during their migratory seasons. Any newly identified ecologically sensitive sites should be avoided from encroaching and disturbance by the Project.
• Implement mitigation measures such as habitat reinstatement, compensation, and the provision of wildlife corridors to minimize ecological impacts. However, as the effectiveness and efficiency of mitigation measures are very limited for intact or unspoiled habitats, top priority should accord to avoidance rather than mitigation or compensation of habitat and/or ecological function loss.
• Ensure compliance with the “zero discharge policy” for Deep Bay, as any untreated surface runoff generated during construction and operation phases should be prevented from discharging into the Ngau Tam Mei Drainage Channel or its tributaries. Stormwater discharged from the Project in operation phase should be treated properly before discharging into any natural or manmade channels, e,g. Sustainable Urban Drainage System.
2. Air Quality
According to EPD’s Air Quality and health Index data, Yuen Long District, where the Project is located, is one of districts highly prone to air pollution. The Project proponent must:
• Assess cumulative air quality impacts from the Project and other nearby developments, such as the San Tin Technopole and Ngau Tam Mei.
• Formulate effective mitigation measures to control air pollution, including promotion of public transport, limiting the parking spaces of private cars, etc.
• Monitor and manage dust emissions during construction, following the measures outlined in the Air Pollution Control (Construction Dust) Regulations.
3. Waste Management
Given the rural nature of the areas adjoining the Project site, fly-tipping of solid wastes generated from the Project must be strictly controlled. We recommend:
• Strict monitoring and control of the storage, transportation, and disposal of solid wastes.
• Incorporation of mitigation measures into the works contract to prevent illegal dumping.
• Implementation of a comprehensive recycling plan to promote a zero-waste project.
• GPS tracking and instantaneous alarm systems for dump trucks entering restricted zones (e.g., Lam Tsuen Country Park, Wetland Conservation and Buffer Area, potential Wetland Conservation Parks, etc).
4. Water Quality
The Project’s alignment passes through areas connected to the Mai Po Inner Deep Bay Ramsar Site. To protect the ecology of the Ramsar Site, we propose:
• Prevention of untreated surface runoff from discharging into the Ngau Tam Mei Drainage Channel or its tributaries.
• Incorporation of a sustainable urban drainage system to treat polluted surface runoff and promote climate resilience.
• Adoption of mitigation measures to manage construction site runoff and prevent water pollution.
5. Tunnel Construction
According to Section 3.1.1, the Project will involve land-based construction works… conceptually be made up of … Construction of tunnel by both Drill & Blast (D&B). Surprisingly, its risks and potential impacts are not fully addressed in PP. No corresponding mitigation measures are proposed to reduce the impacts of
(a) blasting noise on the noise sensitive receivers;
(b) blasting vibration and no receivers vulnerable to blasting vibration are identified;
(c) blasting vibration on the geotechnical stability the nearby slopes.
Also, potential risk of blasting on Ngau Tam Mei Landfill should be assessed and location(s) of magazine has not been mentioned in PP.
6. Cultural Heritage
The Project alignment encroaches into archaeological potential areas identified in previous EIA reports. We recommend:
• Conducting a Cultural Heritage Impact Assessment to assess potential impacts on cultural heritage resources.
• Implementing mitigation measures to minimize impacts on cultural heritage, with prior agreement from the Antiquities and Monuments Office.
7. Cumulative Environmental Impacts
Given the proximity of the Project to other major developments, such as the San Tin Technopole and Northern Link, it is crucial to assess the cumulative environmental impacts. We stress the importance of including all potential environmental impacts of adjacent developments in the current EIA to avoid underestimation.
8. Public Consultation
We urge the Project proponent to arrange public consultations once sufficient information is available. This will ensure that the concerns of the local community and environmental groups are addressed.
Thank you for your attention to these matters. 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
