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 submits the following concerns and recommendations regarding the environmental implications of the above-captioned Project Profile (PP). We reference our earlier submission on similar projects (Smart and Green Mass Transit Systems in Kai Tak and East Kowloon, 31 July 2024) and stress the need for rigorous environmental safeguards.
Types of Mass Transit System Not Yet Proposed
1. The PP only stated that the proposed “SGMTS-EK is a light and green, electrically powered transit system of medium to low carrying capacity operating on a dedicated corridor” (PP Section 1.2.4 & 3.1.1) but have not indicated the type (monorails, light rails, trolleybus, trams, etc), scale of the structures, footprint of each GTS and their ancillary facilities. Green Power opines that the environmental impacts cannot be correctly identified and then no competent EIA can be conducted.
2 Different types of SGMTS-EK may have different passenger carrying capacity and structural design that leads to different project footprint, civil engineering design and works area/boundary during construction phase. These basic engineering factors affect the extent and amplitude of environmental impacts in both construction and operation phases.
3. In view of the vicinity of the proposed projects to residential areas and sensitive receivers such as schools and elderly homes, Study Briefs and/or Environmental Permit should be issued only if the types, scale, passenger capacity and alignment options of SGMTS-EK have been proposed.
Enhanced Carrying Efficiency and Pedestrian Connectivity
4. The PP states the Project aims to address commuting needs through a feeder transit system (PP Section 1.2.1). To ensure its effectiveness, the system should achieve carrying efficiency superior to existing road-based services. We recommend:
• Clear benchmarks for passenger capacity, frequency, and reliability to reduce reliance on private vehicles.
• Weather-resilient and barrier-free pedestrian linkage facilities connecting stations of the Project to existing MTR stations and residential areas (e.g., Anderson Road Quarry site) to lower vulnerability of commuters and pedestrains to extreme heat and torrential rains.
Avoidance of Tree Felling and Urban Heat Island Mitigation
5. The alignment passes through densely vegetated areas (PP Section 3.1.11). Tree removal exacerbates urban heat and reduces ecological resilience. We urge:
• Zero tree felling policy unless absolutely unavoidable, with compensatory planting for unavoidable losses with standard-sized trees of native species with compensation ratio higher than 1.
• Vertical greening on viaducts, stations and depot to offset heat island effects.
Protection of Water Channels and Aquatic Ecology
6. The Ma Yau Tong Depot construction risks encroachment on natural streams (PP Section 3.1.11). We demand:
• No-works buffer zones (minimum 30m) around natural watercourses to prevent pollution and hydrological disruption.
• Sustainable drainage systems (e.g., bioswales, rain gardens) to treat runoff and protect water quality.
Noise and Vibration Risks to Sensitive Receivers
7. The alignment passes schools (e.g., Ping Shek Estate Catholic Primary School) and heritage sites (St. Joseph’s Home for the Aged, Grade 2) (PP Table 4.1.1). Drill-and-blast tunnelling poses risks of ground-borne vibration. Mitigation must include:
• Low-noise track technology (e.g., rubber-tyred systems) and full enclosures for viaducts near NSRs.
• Pre-construction structural surveys for heritage buildings to monitor vibration impacts (PP Section 5.2.14).
Cumulative Impacts from Concurrent Projects
8. The Project interfaces with developments like the Anderson Road Quarry site and Tseung Kwan O–Lam Tin Tunnel (PP Section 2.3.1). We recommend:
• Integrated assessment of cumulative air/noise impacts, particularly near landfill consultation zones (Ngau Chi Wan, Ma Yau Tong Central Landfills).
• Proactive mitigation for landfill gas hazards during tunnelling (PP Section 5.2.26), including real-time gas monitoring.
Unaddressed “Smart” Technology Risks
9. The PP vaguely references “smart technologies” without environmental or health evaluations (e.g., electromagnetic fields). We insist on:
• Full disclosure of technologies involved and compliance with WHO guidelines.
• Health impact assessments for electromagnetic exposure near schools and residences.
10. In case that such “smart” and “green” facilities have not been included in the subsequently issued Study Briefs, their associated environmental impacts may be “officially” omitted in the whole EIA process that violates the purpose and spirit of EIAO.
11. The environmental performance of proposed SGMTS-EK should also be quantified to verify its “green” claims, such as reduction in CO2-equivalent, air and water pollutants, noise level, amount of waste generated.
Ecological Compensation and Habitat Connectivity
12. The MYT Depot construction will cause woodland and watercourse loss (PP Section 3.1.11). Mitigation must include:
• Year-round ecological surveys for wildlife.
• Wildlife corridors to reconnect fragmented habitats.
Green Power urges the EPD to mandate these measures in the EIA Study terms of reference. We request stakeholder consultation and review of the draft EIA report.
Thank you for your attention. For inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).
Green Power submits the following concerns and recommendations regarding the environmental implications of the above-captioned Project Profile (PP). We reference our earlier submission on similar projects (Smart and Green Mass Transit Systems in Kai Tak and East Kowloon, 31 July 2024) and stress the need for rigorous environmental safeguards.
Types of Mass Transit System Not Yet Proposed
1. The PP only stated that the proposed “SGMTS-EK is a light and green, electrically powered transit system of medium to low carrying capacity operating on a dedicated corridor” (PP Section 1.2.4 & 3.1.1) but have not indicated the type (monorails, light rails, trolleybus, trams, etc), scale of the structures, footprint of each GTS and their ancillary facilities. Green Power opines that the environmental impacts cannot be correctly identified and then no competent EIA can be conducted.
2 Different types of SGMTS-EK may have different passenger carrying capacity and structural design that leads to different project footprint, civil engineering design and works area/boundary during construction phase. These basic engineering factors affect the extent and amplitude of environmental impacts in both construction and operation phases.
3. In view of the vicinity of the proposed projects to residential areas and sensitive receivers such as schools and elderly homes, Study Briefs and/or Environmental Permit should be issued only if the types, scale, passenger capacity and alignment options of SGMTS-EK have been proposed.
Enhanced Carrying Efficiency and Pedestrian Connectivity
4. The PP states the Project aims to address commuting needs through a feeder transit system (PP Section 1.2.1). To ensure its effectiveness, the system should achieve carrying efficiency superior to existing road-based services. We recommend:
• Clear benchmarks for passenger capacity, frequency, and reliability to reduce reliance on private vehicles.
• Weather-resilient and barrier-free pedestrian linkage facilities connecting stations of the Project to existing MTR stations and residential areas (e.g., Anderson Road Quarry site) to lower vulnerability of commuters and pedestrains to extreme heat and torrential rains.
Avoidance of Tree Felling and Urban Heat Island Mitigation
5. The alignment passes through densely vegetated areas (PP Section 3.1.11). Tree removal exacerbates urban heat and reduces ecological resilience. We urge:
• Zero tree felling policy unless absolutely unavoidable, with compensatory planting for unavoidable losses with standard-sized trees of native species with compensation ratio higher than 1.
• Vertical greening on viaducts, stations and depot to offset heat island effects.
Protection of Water Channels and Aquatic Ecology
6. The Ma Yau Tong Depot construction risks encroachment on natural streams (PP Section 3.1.11). We demand:
• No-works buffer zones (minimum 30m) around natural watercourses to prevent pollution and hydrological disruption.
• Sustainable drainage systems (e.g., bioswales, rain gardens) to treat runoff and protect water quality.
Noise and Vibration Risks to Sensitive Receivers
7. The alignment passes schools (e.g., Ping Shek Estate Catholic Primary School) and heritage sites (St. Joseph’s Home for the Aged, Grade 2) (PP Table 4.1.1). Drill-and-blast tunnelling poses risks of ground-borne vibration. Mitigation must include:
• Low-noise track technology (e.g., rubber-tyred systems) and full enclosures for viaducts near NSRs.
• Pre-construction structural surveys for heritage buildings to monitor vibration impacts (PP Section 5.2.14).
Cumulative Impacts from Concurrent Projects
8. The Project interfaces with developments like the Anderson Road Quarry site and Tseung Kwan O–Lam Tin Tunnel (PP Section 2.3.1). We recommend:
• Integrated assessment of cumulative air/noise impacts, particularly near landfill consultation zones (Ngau Chi Wan, Ma Yau Tong Central Landfills).
• Proactive mitigation for landfill gas hazards during tunnelling (PP Section 5.2.26), including real-time gas monitoring.
Unaddressed “Smart” Technology Risks
9. The PP vaguely references “smart technologies” without environmental or health evaluations (e.g., electromagnetic fields). We insist on:
• Full disclosure of technologies involved and compliance with WHO guidelines.
• Health impact assessments for electromagnetic exposure near schools and residences.
10. In case that such “smart” and “green” facilities have not been included in the subsequently issued Study Briefs, their associated environmental impacts may be “officially” omitted in the whole EIA process that violates the purpose and spirit of EIAO.
11. The environmental performance of proposed SGMTS-EK should also be quantified to verify its “green” claims, such as reduction in CO2-equivalent, air and water pollutants, noise level, amount of waste generated.
Ecological Compensation and Habitat Connectivity
12. The MYT Depot construction will cause woodland and watercourse loss (PP Section 3.1.11). Mitigation must include:
• Year-round ecological surveys for wildlife.
• Wildlife corridors to reconnect fragmented habitats.
Green Power urges the EPD to mandate these measures in the EIA Study terms of reference. We request stakeholder consultation and review of the draft EIA report.
Thank you for your attention. For 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
