政策倡議及咨詢

Green Power has reviewed the Environmental Impact Assessment (EIA) Report (the Report) for the captioned Project (the Project). While we note that some of our earlier concerns raised during the Project Profile consultation have been partially addressed in Table 2.6 of the EIA Report, we remain highly concerned about several critical environmental issues that have not been adequately resolved or sufficiently mitigated. We hope the following concerns are fully addressed and corresponding measures are incorporated into the Environmental Permit.

‍Key Recommendations from Public Submissions

1. While the Report responds to some public comments, it does not adopt several specific recommendations we raised in our 2020 submission, such as prohibiting all works vehicles from accessing South Lantau Road, implementing a vessel speed monitoring system, and conducting a comprehensive cumulative air pollution impact assessment.

‍Air Quality

2. The EIA Report (Section 3.3.1.2, Table 3.2) acknowledges that ozone (O₃) exceedances have been recorded at the Tung Chung monitoring station, yet O₃ is not included as an assessment parameter in the air quality modelling. The Report states that "O₃ is a complex regional air pollutant that does not directly emit from man-made sources", and that "reducing NOx emissions from vehicles may lead to higher O₃ concentrations". The Report irresponsibly neglect that NOx is one of the major precursors of O₃ in the troposphere. Despite this recognition, the assessment does not model O₃ formation or assess how increased NOx emissions from the Project might exacerbate local O₃ levels, which are already exceeding Air Quality Objectives (AQOs). We insist that O₃ be included in the operational phase assessment using a conservative regional background scenario.

3. While the Report uses PATH v3.0 model predictions for 2030 as background data (Section 3.6.2.30, Table 3.3), it relies on historical monitoring data from 2019–2023 for baseline trends. This does not fully account for future deterioration in regional air quality or the cumulative impact of other potential and planned major projects in the area (e.g., Route 11, Tsing Yi-Lantau Link(TYLL), Sunny Bay Reclamation). We recommend that the operational phase air quality model be re-run using a more conservative background scenario that incorporates projected increases in regional pollution and assesses cumulative impacts with other committed projects.

‍Noise

4. The Report (Section 4.5.1.2) states that "all of the construction works are expected to be carried out during non-restricted hours". However, the Report defers detailed noise mitigation to a Construction Noise Management Plan (CNMP) and does not provide quantitative assessment of blasting or vibration impacts.

‍Water Quality

5. Surface runoff pathways to water sensitive receivers and ecologically sensitive sites, such as Yan O Bay and Tai Ho Bay should be identified in the Report. These pathways may drain sewage and/or contaminated surface runoff to these sensitive receivers and sites during rainstorms, failure/mistreatment of sedimentation tanks, chemical spillages, etc. During construction phase, measures such as dykes, sheet pilings should be installed to block these surface runoff pathways to protect the water quality and ecology. In operation phase, the outfalls or discharge points of stormwater drainage network of the Project should not be fed to these water sensitive receivers and ecologically sensitive sites.

6. Dismissing cumulative water quality impacts based on nonavailability of "construction phasing / works sequence or details on the marine works method / mitigation measures" for other potential and planned major concurrent projects is too optimistic. More conservative modeling scenarios assuming concurrent works and a formal inter-project coordination mechanism are recommended.

‍Waste Management and Land Contamination

7. While the Report (Section 6.5.1.11) mentions the implementation of vehicle GPS tracking and a trip‑ticket system for construction waste, it does not specify clear "No‑go" zones to prevent vehicles from entering ecologically sensitive areas such as the Tai Ho Stream SSSI, Tung Chung West, Tung Chung River basin and Tung Chung Bay, and other nearby marine and coastal habitats. Furthermore, the Report lacks enforceable penalty clauses and real‑time alert mechanisms in contracts to deter and promptly address route deviations or illegal dumping. We request that such zones and contractual controls be explicitly defined in the Environmental Permit.

8. The Report does not commit to installing physical fencing around worksites to restrict vehicle and personnel access to natural coastlines outside the designated work areas. Without such physical barriers, there remains a tangible risk of construction waste, sediment run‑off or accidental spills entering adjacent waters, potentially harming marine ecology. This is especially critical given the Project’s proximity to Yan O Wan and other sensitive coastal habitats.

9. Regarding land contamination, Section 7.5.9.1 of the EIA Report identifies two sites (Former HyD Site Office CS‑7 and LCSD Depot CS‑8) with potential oil‑stain and chemical‑storage issues. Although the Report proposes further site reappraisal and supplementary Contamination Assessment Plans (CAPs) prior to construction, it does not integrate these land contamination controls with the overall waste management and site‑runoff mitigation measures. We urge that the Waste Management Plan (WMP) explicitly include procedures to handle potentially contaminated soil and groundwater encountered during excavation, and that all stockpiling areas for such materials be fully lined, bunded and covered to prevent leaching into surrounding land and waters.

10. The sediment management approach (Section 6.5.1.15‑23) appropriately prioritises on‑site reuse of Category L sediment and outlines marine disposal procedures for other categories. However, the Report does not commit to real‑time monitoring of sediment‑handling and barge‑loading operations to prevent spillage during marine transport. Given the ecological sensitivity of northern Lantau waters, we recommend that the Environmental Permit require the contractor to implement visual and electronic monitoring (e.g., CCTV at loading points, Front End Mobile Unit (FEMU) tracking as mentioned) with clear trigger‑action plans for any accidental releases.

11. The Report's waste management measures are largely procedural and rely on contractor‑prepared plans (e.g., WMP, C&DMMP). To ensure accountability, we request that key performance indicators (e.g., maximum allowable waste generation rates, recycling targets, incident reporting timelines) be stipulated in the Environmental Permit, along with mandatory environmental training for all construction personnel—covering not only waste segregation and chemical handling but also the protection of adjacent ecological resources.

‍Ecology

12. While surveys covered dry and wet seasons, the Report acknowledges that some species of conservation importance were recorded only in unpublished AFCD data (from 2002 to 2021) or historical studies. The reliance on secondary data for certain taxa (e.g., some bats, freshwater species) may under-represent current ecological conditions. Future monitoring should include targeted surveys for these data-deficient species, especially before construction begins, to ensure no overlooked populations are present.

13. Several impacts—such as the loss of modified watercourse habitat supporting Romer's tree frog and lesser spiny frog—are evaluated as "Low to Moderate" but are then described as having "Minor" overall significance (Section 8.7.2.10). This appears inconsistent, especially given the protected status of these species. Impacts on legally protected species and their habitats should be consistently classified with precaution, and mitigation should be explicit and species-specific.

14. The cumulative impacts section is brief and does not thoroughly assess the combined effects of this Project with other ongoing developments in North Lantau (e.g., Route 11, TYLL). The focus remains largely project-specific. A dedicated cumulative ecological impact assessment should be conducted, considering spatial and temporal overlap with other projects, especially in marine areas used by Chinese White Dolphins.

15. The Report notes that Chinese White Dolphin activity is higher at night in the area, yet construction mitigation focuses mainly on daytime controls. Similarly, impacts on nocturnal fauna (e.g., bats, owls) from lighting and noise are only generally addressed. Specific nighttime construction restrictions, dark-sky compliant lighting, and acoustic monitoring during night hours should be mandated in sensitive zones.

16. In order to protect ecologically important Yan O Bay and Tai Ho Stream SSSI and avoid triggering uncontrollable development pressures on Lantau, the works area of the Project should be clearly defined and fenced with restricted vehicular and pedestrian access. The project proponent, their contractors and subcontractors should not use any of the land areas on Lantau coast outside the works area especially Tung Chung West, Pak Mong, Ngau Kwu Long, Tai Ho, Tai Ho Wan, Yan O Wan, Yam O Tuk, Luk Keng Tsuen, Luk Keng Bay, Cheung Sok, Ha Kok Tsui, Yam Tsai Wan and undeveloped coastlines and areas on the outlying islands as works area, vehicle parking, vessel berthing, equipment storage, stock piling or other activities related to proposed works of the Project.

‍Fisheries

17. The Report acknowledges a permanent loss of approximately 15.5 hectares of fishing grounds but classifies the impact as "Minor" due to low commercial value and small scale relative to Hong Kong waters. However, the cumulative loss from multiple projects in North Lantau is not sufficiently quantified, and the assumption of "temporal separation" with other major developments is optimistic. A cumulative fisheries impact assessment should be conducted, considering all concurrent and planned projects in the region, and a fisheries enhancement or compensation plan should be clearly outlined in the Environmental Permit.

‍Environmental Monitoring and Audit

18. Ecological monitoring focuses only on water quality, with no dedicated monitoring plan for key species such as Chinese White Dolphin, pipefish, and corals.

19. The frequency of environmental audits during construction (e.g., weekly) may be insufficient to effectively prevent non-compliance. We recommend increased inspection frequency and the establishment of a real-time monitoring system.

20. There is no clear requirement for all construction personnel to receive ecological protection training, nor a ban on feeding wildlife or bringing pets onto the worksite.

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).