Dr. CHUI Ho Kwong, Samuel, J.P.
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)
Green Power, a local charitable environmental group, would like to draw your kind attention to our concerns about the above-captioned Project Profile (PP).
1. The proposed ground investigation (GI) works for Underground Quarrying at Sham Shui Kok (the Project) would include the following (Sec. 4.1.2) within Lantau North (Extension) Country Park (LN(E)CP):
(a) Set up of temporary access ladders and temporary working platforms;
(b) Digging of inspection pits and trial pits manually;
(c) Mobilization of drill rigs by helicopter;
(d) Drilling works at drillholes; and
(e) Site reinstatement works.
2. Regrettably, we opine that the PP has not addressed the site-specific and works-specific environmental issues that cannot constitute a competent Environmental Permit (EP). In view of the remoteness and intactness of the Project site, adequate and enforceable protective and surveillance measures have not been explored, investigated and deployed in this roughly written PP. This application is particularly dangerous for it will obtain a direct issuance of EP without further public consultation. Thus, this PP should be further improved.
Encroachment of Country Park
3. All the proposed GI works within LN(E)CP are located in plantation or shrubland (a total excavation area of approximately 6m2) with several working platforms (with dimensions 3m x 6m for trial pits and 6m x 15m for drillholes respectively) connected by temporary access ladders (about 0.7m width) which will be laid within plantation and shrubland (Sec. 4.6.1).
4. We are worried that PP did not indicate the exact number of working platforms. Any additional working platforms required access ladders to connect that will disturb or even remove vegetation. Such unclear works footprint is indulgent in an intact and pristine area in LN(E)CP which is established to compensate for the massive loss of environmental and ecological assets to developments in North Lantau.
5. Therefore, the works boundary, areas, quantity and material of structures involved should be clearly bounded in EP.
6. Although the proposed access ladders are connected to footpaths in LN(E)CP as indicated in Figure 1.1 in PP, its feasibility for transporting construction materials or as an access for workers under relevant regulations/ordinances have not been confirmed in PP. The PP also did not clearly designate which footpaths will be used under the Project. Then, excessive number of footpaths may be taken up or, even worsen, new accesses will be opened up unnecessarily. Both situations will lead to unexpected additional environmental and ecological impacts that have not been anticipated and assessed in this PP.
7. On the other hand, the access restriction for the public to use the footpaths taken up by the Project has not been proposed in the PP. Access control due to works need cautious considerations, especially for the safety and convenience Country Parks goers.
8. Control measures of footpaths should be proposed and approved by relevant authorities in prior to be included in EP.
9. Unloading points, including backup options, for transportation of materials and equipment (Sec.5.5.3) by helicopters should be proposed and approved by the relevant authorities, and included in EP. No additional land access should be allowed if any unloading points or helicopter flights are failed to work.
Wildlife Disruption
10. “Detailed” protection measures for the identified species of conservation importance at/near the proposed works (Sec. 5.5.5) should be clearly stated in EP regarding the species involved and locations, if applicable.
11. The works boundary and access of the Project Site should be clearly delineated and physically fenced to prevent trespassing by project personnel to neighbouring habitats. The LN(E)CP and any identified and potential ecologically sensitive areas and species of concern should not be occupied, encroached or disturbed by works agents including but not limited to contractors, subcontractors, suppliers and associated service providers for related uses such as site offices, material/equipment/machinery installation and storage, stock piling, carparks, canteens, etc.
12. The locations of proposed trial pits/ drillholes and temporary access ladders should be adjusted on site to avoid encroachment onto trees (Sec. 5.5.2). Felling of trees and unnecessary trimming/pruning of tree branches/canopies should be avoided in the works areas and in nearby areas. No wastewater should be spilled and no machineries should be placed on tree roots.
13. A formal briefing/ induction to the workforce to reinforce the message that the works are being conducted within LN(E)CP which is an ecologically sensitive area and precautionary measures such as to remind the construction worker not to enter areas secured by protective barriers to avoid impacts to wildlife should be taken (Sec. 5.5.5).
14. All personnel and workers of the Project should not poach or collect any wildlife or plants in the works areas and in LN(E)CP. Also, no feeding of wildlife including but not limited to animals, birds and fishes by them is allowed. Dogs, cats or other domestic animals must be strictly prohibited to be kept in the Project Site.
15. General refuse comprising food scraps, wastepaper, empty containers, etc. would be generated from workers under the Project which would be stored at rubbish bins on site (Sec 4.5.2). Although refuse bins covered with lids are proposed to be provided on-site (Sec. 5.4.1), no night-time works are anticipated for the proposed GI works (Sec. 4.6.6.) and thus the refuse will very likely be fed by wildlife and/or scattered around the Project site by wind.
16. So, it is recommended to clean the construction sites on a daily basis. On-site generated refuse should be removed every day when workers leave the Project site. No general refuse, especially food waste, is allowed to be remained in LN(E)CP and the Project site overnight (Sec. 5.3.2).
17. Dumping of cement and other materials related to the works and/or workers should be forbidden in the LN(E)CP, Project site or in vicinity.
18. As the Project site is near to the popular hiking trail between Discovery Bay and Sunny Bay, risk of fire hills imposed by the Project should be eliminated as practiceable as possible. No smoking or fire ignition is allowed in Project site. Inflammable materials and chemicals/fuel should not be stored in the works areas. Relevant personnel and workers should be notified in this regard before entering the work areas. Suitable fire-fighting equipment should be in place in the work sites.
Surface Runoff
19. The Project area is located within LN(E)CP, work site should not encroach or disturb the courses, beds and banks of permanent, ephemeral or intermittent streams to avoid water pollution and habitat damages. Any sewage, wastewater and wastes should be removed from the works sites/areas on daily basis.
20. The locations of proposed trial pits/ drillholes and temporary access ladders should be adjusted on site to avoid encroachment onto watercourses (Sec. 5.5.2).
21. Exposed soil surface should be covered with tarpaulin or similar fabric when no works are conducted. Excavated and filled surfaces that are susceptible to erosion should be consistently protected to prevent any erosion (Sec.5.3.2). The excavated soil placed within the temporary working platform should be stored in tough and concealed packaging (Sec. 4.5.1)
22. Chemicals, fuels, hazardous and dangerous goods should not be allowed to store in the Project Site and should be removed from the Project Site when no works activities are implementing and/or no personnel stays in the Project Site.
23. Excavated materials and waste generated from the Project site must be disposed of in licit facilities only and prohibited to be dumped in other places. Effective monitoring system should be in place during the works and strict deterrent clauses should be included in the EP and incorporated in the work contracts to monitor and penalize any fly-tipping activities.
Reinstatement
24. The excavated trial pits should be be backfilled with the uncontaminated on-site excavated material upon the completion of GI works (Sec 5.4.1) to avoid soil contamination and introduction of invasive species.
25. The disturbed grounds by the Project should be reinstated properly. No permanent habitat loss or deterioration of habitats should be resulted (Sec. 5.5.4). Effective measures should be included in EP to enhance natural succession of vegetation and prevent soil erosion of reinstated sites (Sec. 4.6.2), e.g covering the reinstated soil surface with natural mulching materials.
26. Any temporary access and work site should be reinstated to avoid long-term ecological and environmental impacts, and soil erosion to the satisfaction of relevant departments such as AFCD, EPD, GEO of CEDD, etc.
27. The project proponent should be responsible for removal of any wastes for their reinstatement of access and works sites.
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, a local charitable environmental group, would like to draw your kind attention to our concerns about the above-captioned Project Profile (PP).
1. The proposed ground investigation (GI) works for Underground Quarrying at Sham Shui Kok (the Project) would include the following (Sec. 4.1.2) within Lantau North (Extension) Country Park (LN(E)CP):
(a) Set up of temporary access ladders and temporary working platforms;
(b) Digging of inspection pits and trial pits manually;
(c) Mobilization of drill rigs by helicopter;
(d) Drilling works at drillholes; and
(e) Site reinstatement works.
2. Regrettably, we opine that the PP has not addressed the site-specific and works-specific environmental issues that cannot constitute a competent Environmental Permit (EP). In view of the remoteness and intactness of the Project site, adequate and enforceable protective and surveillance measures have not been explored, investigated and deployed in this roughly written PP. This application is particularly dangerous for it will obtain a direct issuance of EP without further public consultation. Thus, this PP should be further improved.
Encroachment of Country Park
3. All the proposed GI works within LN(E)CP are located in plantation or shrubland (a total excavation area of approximately 6m2) with several working platforms (with dimensions 3m x 6m for trial pits and 6m x 15m for drillholes respectively) connected by temporary access ladders (about 0.7m width) which will be laid within plantation and shrubland (Sec. 4.6.1).
4. We are worried that PP did not indicate the exact number of working platforms. Any additional working platforms required access ladders to connect that will disturb or even remove vegetation. Such unclear works footprint is indulgent in an intact and pristine area in LN(E)CP which is established to compensate for the massive loss of environmental and ecological assets to developments in North Lantau.
5. Therefore, the works boundary, areas, quantity and material of structures involved should be clearly bounded in EP.
6. Although the proposed access ladders are connected to footpaths in LN(E)CP as indicated in Figure 1.1 in PP, its feasibility for transporting construction materials or as an access for workers under relevant regulations/ordinances have not been confirmed in PP. The PP also did not clearly designate which footpaths will be used under the Project. Then, excessive number of footpaths may be taken up or, even worsen, new accesses will be opened up unnecessarily. Both situations will lead to unexpected additional environmental and ecological impacts that have not been anticipated and assessed in this PP.
7. On the other hand, the access restriction for the public to use the footpaths taken up by the Project has not been proposed in the PP. Access control due to works need cautious considerations, especially for the safety and convenience Country Parks goers.
8. Control measures of footpaths should be proposed and approved by relevant authorities in prior to be included in EP.
9. Unloading points, including backup options, for transportation of materials and equipment (Sec.5.5.3) by helicopters should be proposed and approved by the relevant authorities, and included in EP. No additional land access should be allowed if any unloading points or helicopter flights are failed to work.
Wildlife Disruption
10. “Detailed” protection measures for the identified species of conservation importance at/near the proposed works (Sec. 5.5.5) should be clearly stated in EP regarding the species involved and locations, if applicable.
11. The works boundary and access of the Project Site should be clearly delineated and physically fenced to prevent trespassing by project personnel to neighbouring habitats. The LN(E)CP and any identified and potential ecologically sensitive areas and species of concern should not be occupied, encroached or disturbed by works agents including but not limited to contractors, subcontractors, suppliers and associated service providers for related uses such as site offices, material/equipment/machinery installation and storage, stock piling, carparks, canteens, etc.
12. The locations of proposed trial pits/ drillholes and temporary access ladders should be adjusted on site to avoid encroachment onto trees (Sec. 5.5.2). Felling of trees and unnecessary trimming/pruning of tree branches/canopies should be avoided in the works areas and in nearby areas. No wastewater should be spilled and no machineries should be placed on tree roots.
13. A formal briefing/ induction to the workforce to reinforce the message that the works are being conducted within LN(E)CP which is an ecologically sensitive area and precautionary measures such as to remind the construction worker not to enter areas secured by protective barriers to avoid impacts to wildlife should be taken (Sec. 5.5.5).
14. All personnel and workers of the Project should not poach or collect any wildlife or plants in the works areas and in LN(E)CP. Also, no feeding of wildlife including but not limited to animals, birds and fishes by them is allowed. Dogs, cats or other domestic animals must be strictly prohibited to be kept in the Project Site.
15. General refuse comprising food scraps, wastepaper, empty containers, etc. would be generated from workers under the Project which would be stored at rubbish bins on site (Sec 4.5.2). Although refuse bins covered with lids are proposed to be provided on-site (Sec. 5.4.1), no night-time works are anticipated for the proposed GI works (Sec. 4.6.6.) and thus the refuse will very likely be fed by wildlife and/or scattered around the Project site by wind.
16. So, it is recommended to clean the construction sites on a daily basis. On-site generated refuse should be removed every day when workers leave the Project site. No general refuse, especially food waste, is allowed to be remained in LN(E)CP and the Project site overnight (Sec. 5.3.2).
17. Dumping of cement and other materials related to the works and/or workers should be forbidden in the LN(E)CP, Project site or in vicinity.
18. As the Project site is near to the popular hiking trail between Discovery Bay and Sunny Bay, risk of fire hills imposed by the Project should be eliminated as practiceable as possible. No smoking or fire ignition is allowed in Project site. Inflammable materials and chemicals/fuel should not be stored in the works areas. Relevant personnel and workers should be notified in this regard before entering the work areas. Suitable fire-fighting equipment should be in place in the work sites.
Surface Runoff
19. The Project area is located within LN(E)CP, work site should not encroach or disturb the courses, beds and banks of permanent, ephemeral or intermittent streams to avoid water pollution and habitat damages. Any sewage, wastewater and wastes should be removed from the works sites/areas on daily basis.
20. The locations of proposed trial pits/ drillholes and temporary access ladders should be adjusted on site to avoid encroachment onto watercourses (Sec. 5.5.2).
21. Exposed soil surface should be covered with tarpaulin or similar fabric when no works are conducted. Excavated and filled surfaces that are susceptible to erosion should be consistently protected to prevent any erosion (Sec.5.3.2). The excavated soil placed within the temporary working platform should be stored in tough and concealed packaging (Sec. 4.5.1)
22. Chemicals, fuels, hazardous and dangerous goods should not be allowed to store in the Project Site and should be removed from the Project Site when no works activities are implementing and/or no personnel stays in the Project Site.
23. Excavated materials and waste generated from the Project site must be disposed of in licit facilities only and prohibited to be dumped in other places. Effective monitoring system should be in place during the works and strict deterrent clauses should be included in the EP and incorporated in the work contracts to monitor and penalize any fly-tipping activities.
Reinstatement
24. The excavated trial pits should be be backfilled with the uncontaminated on-site excavated material upon the completion of GI works (Sec 5.4.1) to avoid soil contamination and introduction of invasive species.
25. The disturbed grounds by the Project should be reinstated properly. No permanent habitat loss or deterioration of habitats should be resulted (Sec. 5.5.4). Effective measures should be included in EP to enhance natural succession of vegetation and prevent soil erosion of reinstated sites (Sec. 4.6.2), e.g covering the reinstated soil surface with natural mulching materials.
26. Any temporary access and work site should be reinstated to avoid long-term ecological and environmental impacts, and soil erosion to the satisfaction of relevant departments such as AFCD, EPD, GEO of CEDD, etc.
27. The project proponent should be responsible for removal of any wastes for their reinstatement of access and works sites.
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
