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, a local charitable environmental organization, submits the following comments on the captioned Project Profile (PP). While we acknowledge the project proponent’s efforts to adopt Tunnel Boring Machine (TBM) methods to minimize surface disturbance, we raise concerns about insufficient ecological safeguards, methodological flaws, and inadequate mitigation measures.
Ecological Impacts and Compensation
1 The alignment passes beneath the Ecological Area (EA) of Lok Ma Chau Loop Development (the Loop)(Sec. 3.7.3) and Shek Wu Wai Wet Agricultural Lands (Sec. 3.7.5), both supporting species of conservation importance (e.g., Greater Painted-snipe). Although the PP states “indirect impacts” to these habitats, EIA should include baseline ecological data for not less than 12 months, quantifiable compensation targets and corresponding EM&A.
2. The achievement of the proposed habitat compensation (Sec. 5.7.1) as a “key measure” is highly ambiguous. Previous projects (e.g., Northern Link EIA-301/2023 under the same project proponent) demonstrated the established artificial/compensatory wetlands often fail to replicate the lost habitats to development projects. In terms of function, the current West Rail Compensation Wetlands have demonstrated that these artificial wetlands may not perform as expected nor have the same capacity to accommodate the target species (e.g. Greater Painted Snipe) as the wetlands they replaced. We demand:
(i) Avoidance of loss and disturbance of wetlands be accorded the highest priority;
(ii) Prohibition of the practice that reclaiming the wetlands and farmlands for works in construction stage and reinstating in operation stage, for such practice have been proven detrimental to ecology;
(iii) Baseline ecological, hydrological and environmental surveys covering seasonal variations (especially for migratory birds) for EIA;
(iv) Habitat compensation aiming at ecological enhancement in terms of area, hydrology and vegetation;
(v) Explicit details, objectives and targets (e.g., area, species abundance) for habitat compensation;
(vi) Compensation habitats should be established and operated in prior to any disturbance and works in affected habitats commence;
(vii) Independent monitoring of compensation wetlands, with penalties for underperformance.
3. The PP omits assessment of Eurasian Otter (Lutra lutra), recently recorded around the Project site. An updated survey and species-specific mitigation plan must be included in EIA.
Construction Risks to Sensitive Habitats
4. The use of drill and blast methods (Sec. 3.12.1) near wetlands and fishponds risks structural subsidence and water contamination, as seen during the Express Rail Link construction (2015). The PP lacks:
(i) Subsidence thresholds for above-ground habitats;
(ii) Contingency plans for accidental sludge/bentonite leakage or groundwater pollution.
5. TBM tunneling under the Loop (Sec. 3.7.3) may destabilize soil hydrology critical for wetland ecosystems in EA. A hydrogeological impact assessment must be conducted.
Water Quality Management
6. The PP references ProPECC PN 2/24 (Sec. 5.4.1) but lacks specifics on:
(i) Real-time water quality monitoring at WSRs (e.g. EA in the Loop);
(ii) Zero-discharge compliance for Deep Bay area.
7 Sediment stockpiling near watercourses (Sec. 5.5.2) that risks washout during rainstorms should be prohibited.
Noise and Vibration Control
8. While quiet PME is proposed (Sec. 5.3.1), the PP does not address cumulative noise impacts from concurrent projects (e.g., San Tin Technopole). A 24-hour noise monitoring system should be mandated near NSRs (e.g., San Lung Tsuen).
9. Ground-borne vibration (Sec. 3.3.4) may disturb burrowing species (e.g. Eurasian Otter and kingfishers). The EIA must define acceptable vibration thresholds and mitigation.
Waste Management and Illegal Dumping
10. The PP’s reliance on general practices (e.g. trip-ticket system) (Sec. 5.5.1) mirrors insufficient measures in past projects (e.g. West Rail). We urge for the tracking and monitoring of transport vehicle and barges routes through GPS systems, and opine that control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles from engaging in illegal dumping activities or flytipping. The mitigation measures to prevent illegal and environmentally vandalistic dumping of wastes generated from the Project (e.g. the GPS tracking of dump trucks/barges) should also be incorporated into the specifications of the works contract.
Cumulative Impacts
11. The PP dismisses cumulative impacts (Sec. 2.3.1) despite overlapping with San Tin Technopole and Northern Link Main Line. A cross-project ecological assessment is essential to address habitat fragmentation and air quality degradation.
Transparency and Public Consultation
12. Exclusing to consult green groups in the early planning stage may lead to negligence of major ecological and environmental issues. Omission of issue of Eurasian Otter in this PP clearly exemplifies the defective consequence. We urge for consultation with green groups in the EIA process for the captioned project, especially due to the ecological sensitivity of the Project site.
Emergency Response Plans
13. The PP lacks an Emergency Action Plan for chemical spills (Sec. 3.5.1). Protocols for Dangerous Goods Ordinance (Cap. 295) compliance must be detailed, including spill containment near wetlands.
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, a local charitable environmental organization, submits the following comments on the captioned Project Profile (PP). While we acknowledge the project proponent’s efforts to adopt Tunnel Boring Machine (TBM) methods to minimize surface disturbance, we raise concerns about insufficient ecological safeguards, methodological flaws, and inadequate mitigation measures.
Ecological Impacts and Compensation
1 The alignment passes beneath the Ecological Area (EA) of Lok Ma Chau Loop Development (the Loop)(Sec. 3.7.3) and Shek Wu Wai Wet Agricultural Lands (Sec. 3.7.5), both supporting species of conservation importance (e.g., Greater Painted-snipe). Although the PP states “indirect impacts” to these habitats, EIA should include baseline ecological data for not less than 12 months, quantifiable compensation targets and corresponding EM&A.
2. The achievement of the proposed habitat compensation (Sec. 5.7.1) as a “key measure” is highly ambiguous. Previous projects (e.g., Northern Link EIA-301/2023 under the same project proponent) demonstrated the established artificial/compensatory wetlands often fail to replicate the lost habitats to development projects. In terms of function, the current West Rail Compensation Wetlands have demonstrated that these artificial wetlands may not perform as expected nor have the same capacity to accommodate the target species (e.g. Greater Painted Snipe) as the wetlands they replaced. We demand:
(i) Avoidance of loss and disturbance of wetlands be accorded the highest priority;
(ii) Prohibition of the practice that reclaiming the wetlands and farmlands for works in construction stage and reinstating in operation stage, for such practice have been proven detrimental to ecology;
(iii) Baseline ecological, hydrological and environmental surveys covering seasonal variations (especially for migratory birds) for EIA;
(iv) Habitat compensation aiming at ecological enhancement in terms of area, hydrology and vegetation;
(v) Explicit details, objectives and targets (e.g., area, species abundance) for habitat compensation;
(vi) Compensation habitats should be established and operated in prior to any disturbance and works in affected habitats commence;
(vii) Independent monitoring of compensation wetlands, with penalties for underperformance.
3. The PP omits assessment of Eurasian Otter (Lutra lutra), recently recorded around the Project site. An updated survey and species-specific mitigation plan must be included in EIA.
Construction Risks to Sensitive Habitats
4. The use of drill and blast methods (Sec. 3.12.1) near wetlands and fishponds risks structural subsidence and water contamination, as seen during the Express Rail Link construction (2015). The PP lacks:
(i) Subsidence thresholds for above-ground habitats;
(ii) Contingency plans for accidental sludge/bentonite leakage or groundwater pollution.
5. TBM tunneling under the Loop (Sec. 3.7.3) may destabilize soil hydrology critical for wetland ecosystems in EA. A hydrogeological impact assessment must be conducted.
Water Quality Management
6. The PP references ProPECC PN 2/24 (Sec. 5.4.1) but lacks specifics on:
(i) Real-time water quality monitoring at WSRs (e.g. EA in the Loop);
(ii) Zero-discharge compliance for Deep Bay area.
7 Sediment stockpiling near watercourses (Sec. 5.5.2) that risks washout during rainstorms should be prohibited.
Noise and Vibration Control
8. While quiet PME is proposed (Sec. 5.3.1), the PP does not address cumulative noise impacts from concurrent projects (e.g., San Tin Technopole). A 24-hour noise monitoring system should be mandated near NSRs (e.g., San Lung Tsuen).
9. Ground-borne vibration (Sec. 3.3.4) may disturb burrowing species (e.g. Eurasian Otter and kingfishers). The EIA must define acceptable vibration thresholds and mitigation.
Waste Management and Illegal Dumping
10. The PP’s reliance on general practices (e.g. trip-ticket system) (Sec. 5.5.1) mirrors insufficient measures in past projects (e.g. West Rail). We urge for the tracking and monitoring of transport vehicle and barges routes through GPS systems, and opine that control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles from engaging in illegal dumping activities or flytipping. The mitigation measures to prevent illegal and environmentally vandalistic dumping of wastes generated from the Project (e.g. the GPS tracking of dump trucks/barges) should also be incorporated into the specifications of the works contract.
Cumulative Impacts
11. The PP dismisses cumulative impacts (Sec. 2.3.1) despite overlapping with San Tin Technopole and Northern Link Main Line. A cross-project ecological assessment is essential to address habitat fragmentation and air quality degradation.
Transparency and Public Consultation
12. Exclusing to consult green groups in the early planning stage may lead to negligence of major ecological and environmental issues. Omission of issue of Eurasian Otter in this PP clearly exemplifies the defective consequence. We urge for consultation with green groups in the EIA process for the captioned project, especially due to the ecological sensitivity of the Project site.
Emergency Response Plans
13. The PP lacks an Emergency Action Plan for chemical spills (Sec. 3.5.1). Protocols for Dangerous Goods Ordinance (Cap. 295) compliance must be detailed, including spill containment near wetlands.
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
