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 for the above-captioned Project Profile (PP) for the Hong Kong Section of the Hong Kong-Shenzhen Western Rail Link (HSWRL) (the Project).
Ecology
1. The PP identified three egretries (Ngau Hom Shek, Hung Shui Kiu, Tin Shui Wai Hospital) and an ardeid night roost within 1 km of the alignment (Sec. 4.6.1) which are vulnerable to vibration, light pollution, disturbance and encroachment by the Project during construction and operation phase. Buffer zones with noise limits and avian-safe lighting during breeding season should be implemented to avoid the impacts. Baseline surveys for flight-lines and foraging grounds of egretries and night roosting sites should be conducted especially in breeding season of egrets and herons, and wintering season of migratory birds.
2. The Project may affect Deep Bay’s Coastal Protection Areas (“CPA”) (OZP No. S/YL‐HTF/12 and S/YL-LFS/11) (Sec. 4.6.2) with subsidence-induced habitat degradation for endangered Horseshoe Crabs and mangroves. Preventive measures must be implemented to avoid alternation/disturbance/damages to coastal and intertidal habitats, and leakage of bentonite from tunnel to surface, especially wetlands and coastal areas.
3. Eurasian Otter is neglected in PP which should be included in the EIA which is a rare and important wetland species.
Tunnel Construction
4. The locations of ventilation shafts, vertical shafts for tunnel boring machines and other land-based construction were not indicated in PP that seriously omit significant environmental and ecological impacts induced by the Project.
5. Hydrological and hydraulic impacts of tunnels in both construction and operation phase should be assessed and monitored to avoid alternation of surface and groundwater hydrology.
Waste Management
6. 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:
(a) Strict monitoring and control of the storage, transportation, and disposal of solid and C&D wastes.
(b) Incorporation of deterrent measures into the works contracts to prevent illegal dumping.
(c) Implementation of a comprehensive recycling plan to promote a zero-waste project.
(d) GPS tracking and instantaneous alarm systems for dump trucks entering restricted zones (e.g.,
Deep Bay Road, Kai Pak Ling Road, “Conservation Area” zones, Coastal Protection Area” zones. “Green Belt” zones, wetlands and farmlands, etc) to prevent fly-tipping and damage of wetlands and farmlands.
Water Quality
7. The Project’s alignment passes through areas connected to the Mai Po Inner Deep Bay Ramsar Site and in vicinity of oyster beds. To protect the ecology of the Ramsar Site and safeguard the production of oyster farms, we urge:
(a) Prevention of untreated surface runoff from discharging into Tin Shui Wai Nullah and Ha Tsuen Channel or their tributaries, or any drainage channels feeding to Deep Bay.
(b) Adoption of mitigation measures to manage construction site runoff and prevent water pollution.
(c) Sediment/pollutant plume modeling and compensation framework for affected oyster rafts.
(d) The measures forementioned should also be applied to temporary diversion of Ha Tsuen Channel (Sec. 3.4.1).
Climate Resilience
8. Flood risks at at-grade Ha Tsuen Depot should be properly assessed with the consideration of exacerbating extreme climate events (e.g. torrential rainstorms, storm surges), and drainage impacts of neighbouring planned developments.
9. On the other hand, the Ha Tsuen Depot should not impose flood risk to its neighbouring areas with alternation of surface runoff or through stormwater discharge.
Cumulative Impacts
10. PP notes interface with HSK/HT NDA and LFS Study (Sec. 2.3.1) but omits combined impacts of habitat fragmentation. We stress the importance of including all potential environmental impacts of adjacent developments in the current EIA to avoid underestimation.
11. The project should not jeopardise the planning and establishment of Coastal Protection Park across Tsim Bei Tsui-Lau Fau Shan-Pak Nai coast.
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 for the above-captioned Project Profile (PP) for the Hong Kong Section of the Hong Kong-Shenzhen Western Rail Link (HSWRL) (the Project).
Ecology
1. The PP identified three egretries (Ngau Hom Shek, Hung Shui Kiu, Tin Shui Wai Hospital) and an ardeid night roost within 1 km of the alignment (Sec. 4.6.1) which are vulnerable to vibration, light pollution, disturbance and encroachment by the Project during construction and operation phase. Buffer zones with noise limits and avian-safe lighting during breeding season should be implemented to avoid the impacts. Baseline surveys for flight-lines and foraging grounds of egretries and night roosting sites should be conducted especially in breeding season of egrets and herons, and wintering season of migratory birds.
2. The Project may affect Deep Bay’s Coastal Protection Areas (“CPA”) (OZP No. S/YL‐HTF/12 and S/YL-LFS/11) (Sec. 4.6.2) with subsidence-induced habitat degradation for endangered Horseshoe Crabs and mangroves. Preventive measures must be implemented to avoid alternation/disturbance/damages to coastal and intertidal habitats, and leakage of bentonite from tunnel to surface, especially wetlands and coastal areas.
3. Eurasian Otter is neglected in PP which should be included in the EIA which is a rare and important wetland species.
Tunnel Construction
4. The locations of ventilation shafts, vertical shafts for tunnel boring machines and other land-based construction were not indicated in PP that seriously omit significant environmental and ecological impacts induced by the Project.
5. Hydrological and hydraulic impacts of tunnels in both construction and operation phase should be assessed and monitored to avoid alternation of surface and groundwater hydrology.
Waste Management
6. 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:
(a) Strict monitoring and control of the storage, transportation, and disposal of solid and C&D wastes.
(b) Incorporation of deterrent measures into the works contracts to prevent illegal dumping.
(c) Implementation of a comprehensive recycling plan to promote a zero-waste project.
(d) GPS tracking and instantaneous alarm systems for dump trucks entering restricted zones (e.g.,
Deep Bay Road, Kai Pak Ling Road, “Conservation Area” zones, Coastal Protection Area” zones. “Green Belt” zones, wetlands and farmlands, etc) to prevent fly-tipping and damage of wetlands and farmlands.
Water Quality
7. The Project’s alignment passes through areas connected to the Mai Po Inner Deep Bay Ramsar Site and in vicinity of oyster beds. To protect the ecology of the Ramsar Site and safeguard the production of oyster farms, we urge:
(a) Prevention of untreated surface runoff from discharging into Tin Shui Wai Nullah and Ha Tsuen Channel or their tributaries, or any drainage channels feeding to Deep Bay.
(b) Adoption of mitigation measures to manage construction site runoff and prevent water pollution.
(c) Sediment/pollutant plume modeling and compensation framework for affected oyster rafts.
(d) The measures forementioned should also be applied to temporary diversion of Ha Tsuen Channel (Sec. 3.4.1).
Climate Resilience
8. Flood risks at at-grade Ha Tsuen Depot should be properly assessed with the consideration of exacerbating extreme climate events (e.g. torrential rainstorms, storm surges), and drainage impacts of neighbouring planned developments.
9. On the other hand, the Ha Tsuen Depot should not impose flood risk to its neighbouring areas with alternation of surface runoff or through stormwater discharge.
Cumulative Impacts
10. PP notes interface with HSK/HT NDA and LFS Study (Sec. 2.3.1) but omits combined impacts of habitat fragmentation. We stress the importance of including all potential environmental impacts of adjacent developments in the current EIA to avoid underestimation.
11. The project should not jeopardise the planning and establishment of Coastal Protection Park across Tsim Bei Tsui-Lau Fau Shan-Pak Nai coast.
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,
CHENG Luk Ki
Director, GREEN POWER
Yours faithfully,
CHENG Luk Ki
Director, GREEN POWER
