政策倡議及咨詢

BY EMAIL ONLY
30
 
May
 
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,
EIA Report for Expansion of Aberdeen Typhoon Shelter
EIA Report for Expansion of Aberdeen Typhoon Shelter

Green Power would like to draw your kind attention to our concerns about the EIA Report for the proposed Expansion of Aberdeen Typhoon Shelter (ATS) (the Project).

Effective Implementation of Eco-shoreline Features    

1. Evidences to support that “The subtidal portion of the proposed and modified breakwaters will create approximately 4.55 ha of artificial hard substrates, which could facilitate the colonisation of corals and other epibenthos” (Sec. 2.3.1.2, Executive Summary) should be provided and followed up by subsequent EM&A.      

2. Regarding the “Enhancement measures such as installation of eco-shoreline features on the proposed and modified breakwaters as well as eco-features on vessel impact protection system (VIPS) would be implemented for the Project, which could create about 4.75 ha and 1380 m of artificial habitats for facilitating colonisation of intertidal and subtidal epifauna” (Sec. 3.5.10, Executive Summary), further details should be provided and approved by relevant authorities:      

(i) the proposed locations, i.e. horizontal and vertical extent, of eco-shoreline features covering subtidal and tidal zones;

(ii) the reference natural intact shoreline habitat(s) with typical tidal and subtidal species community and population for design of eco-shoreline features and EM&A.

Prevention of Odour Nuisance  

3. During operation phase, pollutants from various sources (Sec. 5.6.31, EIA Report) will be discharged and accumulated in ATS. Owing to the hydrodynamical alternation by the breakwaters, flow rate and turn-over rate of the engulfed water within ATS will be substantially reduced. Hypoxic or anoxic condition will occur with the presence of pollutants under favourable meteorological conditions and/or stratification of water column. As a result, unpleasant smelly gases (e.g. hydrogen sulphide) will be generated by degradation of pollutants and given off from the sediment and/or water column in ATS that will spoil the aesthetic function and cause odour nuisance to the typhoon shelter users and neighbouring residents.

4. Thus, the water flow rate and turn-over rate of ATS should be assessed for the designed breakwaters to forecast the scenarios for formation of hypoxic and anoxic condition throughout the depth of water column in typhoon shelter. The positions and geometry of breakwaters should not create hypoxic or anoxic conditions in favour of smelly gas formation in any part of the ATS.

Confining the Adverse Impacts of Works      

5. The proposed measures to install silt curtains to refrain the dispersal of suspended solid should protect the identified coral colonies from sedimentation.

6. Sediment, C&D waste and chemicals/chemical waste should not be piled or stored on the shore or breakwaters that are vulnerable to be washed down to the sea or ATS during rainstorms or by accident.

7. No works activities, including but not limited to dredging, storage of materials, machines, tools, equipment, parking of vehicles and machineries, should take place or trespass any natural shorelines and geomorphological features, e.g. sea caves and tombolo, and habitats out of the Project works boundary.

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 about the EIA Report for the proposed Expansion of Aberdeen Typhoon Shelter (ATS) (the Project).

Effective Implementation of Eco-shoreline Features    

1. Evidences to support that “The subtidal portion of the proposed and modified breakwaters will create approximately 4.55 ha of artificial hard substrates, which could facilitate the colonisation of corals and other epibenthos” (Sec. 2.3.1.2, Executive Summary) should be provided and followed up by subsequent EM&A.      

2. Regarding the “Enhancement measures such as installation of eco-shoreline features on the proposed and modified breakwaters as well as eco-features on vessel impact protection system (VIPS) would be implemented for the Project, which could create about 4.75 ha and 1380 m of artificial habitats for facilitating colonisation of intertidal and subtidal epifauna” (Sec. 3.5.10, Executive Summary), further details should be provided and approved by relevant authorities:      

(i) the proposed locations, i.e. horizontal and vertical extent, of eco-shoreline features covering subtidal and tidal zones;

(ii) the reference natural intact shoreline habitat(s) with typical tidal and subtidal species community and population for design of eco-shoreline features and EM&A.

Prevention of Odour Nuisance  

3. During operation phase, pollutants from various sources (Sec. 5.6.31, EIA Report) will be discharged and accumulated in ATS. Owing to the hydrodynamical alternation by the breakwaters, flow rate and turn-over rate of the engulfed water within ATS will be substantially reduced. Hypoxic or anoxic condition will occur with the presence of pollutants under favourable meteorological conditions and/or stratification of water column. As a result, unpleasant smelly gases (e.g. hydrogen sulphide) will be generated by degradation of pollutants and given off from the sediment and/or water column in ATS that will spoil the aesthetic function and cause odour nuisance to the typhoon shelter users and neighbouring residents.

4. Thus, the water flow rate and turn-over rate of ATS should be assessed for the designed breakwaters to forecast the scenarios for formation of hypoxic and anoxic condition throughout the depth of water column in typhoon shelter. The positions and geometry of breakwaters should not create hypoxic or anoxic conditions in favour of smelly gas formation in any part of the ATS.

Confining the Adverse Impacts of Works      

5. The proposed measures to install silt curtains to refrain the dispersal of suspended solid should protect the identified coral colonies from sedimentation.

6. Sediment, C&D waste and chemicals/chemical waste should not be piled or stored on the shore or breakwaters that are vulnerable to be washed down to the sea or ATS during rainstorms or by accident.

7. No works activities, including but not limited to dredging, storage of materials, machines, tools, equipment, parking of vehicles and machineries, should take place or trespass any natural shorelines and geomorphological features, e.g. sea caves and tombolo, and habitats out of the Project works boundary.

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,

CHENG Luk Ki
Director, GREEN POWER

Yours faithfully,

CHENG Luk Ki
Director, GREEN POWER

二零二五年
五月
三十日