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's Comments on Environmental Impact Assessment Report for Reclamation at Lung Kwu Tan (EIA-319/2025)
Green Power has reviewed the captioned Environmental Impact Assessment (EIA) Report (the Report). We find that while the Report provides a substantial technical baseline, many of the most critical ecological concerns raised during the Project Profile stage remain unresolved. We urge the following key issues to be fully rectified and stipulated as enforceable conditions in the Environmental Permit.
Unresolved and Unaddressed Ecological Concerns from Project Profile
1. Lung Kwu Tan is an outstanding butterfly hotspot in the Western New Territories. Butterfly habitats, larval food plants and nectary plants are very likely to be encroached or lost for several rare and uncommon species in this recognised hotspot due to site formation, works related land uses (e.g. stock piling, car parks, etc.), flytippings and hillfires. No avoidance or compensation measures are specified in the proponent’s responses (Table 2.7).
2. Habitat of Horseshoe Crab will be lost to the Project. Although there have been no recent official records in the assessment area, past records revealed that the shores of Lung Kwu Tan and Lung Kwu Sheung Tan are their nursery grounds. In view of its conservation status and their occurrence in nearby shores, Survey and mitigation measures should be proposed for this endangered species. However, our concern has not been addressed in the proponent's response table.
3. The assessment of Chinese White Dolphin (CWD) impacts is insufficiently precautionary. Given the critically low and declining population in Northwest Lantau, the permanent loss of ~170 ha of marine habitat should be rated as at least a moderate impact, not "minor". A robust, long-term CWD monitoring and adaptive management plan is required.
Air Quality
4. The pollutant concentration predicted by PATH v3.0 for Years 2028, 2030 and 2035 revealed that "exceedances of 10th highest 8-hr O3 and the peak season O3 concentrations are predicted" (Sec. 3.2.3.4). "O3 is more a regional air pollution problem" may be over-simplified and without any solid evidences. This reckless negligence irresponsibly exposes the public to additional health risk.
5. The Report acknowledged regional O₃ exceedances but dismissed the Project's contribution. An assessment of the Project’s NOx/VOC precursor emissions and a commitment to Best Available Technology (BAT) for all engines must be included.
6. The assessment over-relies on "separation distance" as a primary justification, substituting for detailed quantitative dispersion modelling for fugitive dust from large-scale earthworks. Quantitative air dispersion modelling for peak construction phases should be conducted.
7. Cumulative impacts with other major projects in the NWNT are dismissed based on distance. A qualitative regional cumulative air impact assessment must be provided.
Water Quality
8. Although information regarding the additional pollution loading from the future top-side development is not available at the time of preparing the Report, necessary mitigation should be proposed, executed and in place at current phase to guarantee the validity of the EIA results and avoid jeopardize the effort of proposed mitigation measures.
9. The conclusion that unmitigated impacts would be compliant undermines the necessity of proposed measures. Stringent, real-time performance criteria for silt curtains with explicit contingency plans must be part of the EM&A.
10. The long-term viability of the "green channels" is at high risk of water quality deterioration and eutrophication due to reduced flushing effect. A comprehensive Green Channel Management and Water Quality Plan with long-term monitoring and management responsibility is required, not just 12 months of dissolved oxygen monitoring along the green channels.
11. Moreover, the Environmental Permit must explicitly prohibit any effluent outfalls, stormwater outfalls or wastewater and surface runoff from discharging to water courses and outlets/estuaries of green channels.
12. Cumulative impacts with other major reclamation/dredging projects (e.g., RTT, Sunny Bay) are deferred. A coordinated cumulative water quality impact assessment is essential.
Waste Management & Land Contamination
13. The land contamination assessment is preliminary only. Detailed Site Investigation (SI) and a Contamination Assessment Plan (CAP) must be completed and approved before construction commencement on affected land.
14. The beneficial reuse of dredged sediment lacks a concrete plan. A Sediment Reuse Feasibility Study with clear targets must be required.
15. We agree that all dump trucks/ marine vessels engaged in the Project should be equipped with Global Positioning System (GPS) or equivalent automatic system for real time tracking and monitoring of their travel routings and parking locations to prohibit illegal dumping and landfilling of waste. Therefore, stricter waste transportation tracking and enforcement should be implemented. Mandatory real-time GPS tracking with geofencing for all waste haulage vessels and vehicles, linked to contractual penalties, must be imposed.
Ecology
16. Mitigation for the newly discovered LKST Egretry, located only about 30m from works, should be enhanced with larger buffer zone, construction activity prohibition during the breeding season and a 24-hour disturbance monitoring plan must be implemented.
17. As "the project design has also considered the preservation of the natural watercourse at LKST (FS2) by connecting to the eastern green channel, maintaining the connectivity between FS2 and the nearby marine habitats" (Sec 8.5.1.1), hydraulic, hydrological and water quality parameters should be considered in project design. Buffer zones for natural stream course, especially FS2, should be provided during construction and operation phase because there is highly utilized by different species and they ecologically and hydrologically connect coastal marine habitat to terrestrial habitats.
18. Two Green Channels will be created by adopting eco-shoreline as mitigation measure for marine ecological impacts. To be an effective mitigation measures, the green channels should be established before the commencement of top-side development of the reclamation.
19. The Report highlighted that "the eco-shoreline at Tung Chung East was found to support over 100 different species of marine life, including horseshoe crab at rocky eco-shoreline" (Sec 8.9.5.8). Therefore, recolonization of Horseshoe Crabs is proven feasible and they should NOT be excluded from the ecological mitigation measures and monitoring. However, the Report also mentioned that "Horseshoe crab nursery grounds are characteristically shallow, sheltered intertidal zones with soft sediment" (Sec 8.3.3.10). Suitable substratum should be provided in the eco-shorelines for restoring Horseshoe Crab's nursery ground.
20. In view that eco-shoreline technique is still in its infancy stage in Hong Kong and no local precedent project can be made reference to, ecologists, hydraulic professionals, green groups and other related stakeholders should be consulted for the detailed design of Green Channels regarding:
(a) Identifying their ecological functions that should match the preserved natural shorelines,
(b) Structural dimensions, shape and spatial alignment,
(c) Building materials and construction methods,
(d) Anticipated biotic and abiotic conditions (e.g. proportion and positions of soft and hard substrata) and target species (e.g. Horseshoe Crabs)
(e) The need of plantation, vegetation coverage percentage, planting substratum, plant species selection and long-term management and monitoring,
(f) The need of buffer zones during construction and operation phase.
21. Habitat fragmentation and connectivity impacts are dismissed. A landscape connectivity analysis and measures to maintain terrestrial wildlife corridors are needed.
Landscape & Visual
22. Reliance on future "top-side development" to mitigate the visual impact of the barren reclamation may generate irreversible negative impacts. Mandatory urban design guidelines for the future development must be established now as a permit condition.
In summary, the Report underestimates significant impacts, defers critical mitigation planning, and fails to provide enforceable safeguards for the most sensitive environmental receptors. The Report in its current form is not competent and pre-empt quality EIA for top-side development of the reclamation site. It must be substantially revised to address the fundamental flaws and omissions detailed above before it can be considered for approval.
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's Comments on Environmental Impact Assessment Report for Reclamation at Lung Kwu Tan (EIA-319/2025)
Green Power has reviewed the captioned Environmental Impact Assessment (EIA) Report (the Report). We find that while the Report provides a substantial technical baseline, many of the most critical ecological concerns raised during the Project Profile stage remain unresolved. We urge the following key issues to be fully rectified and stipulated as enforceable conditions in the Environmental Permit.
Unresolved and Unaddressed Ecological Concerns from Project Profile
1. Lung Kwu Tan is an outstanding butterfly hotspot in the Western New Territories. Butterfly habitats, larval food plants and nectary plants are very likely to be encroached or lost for several rare and uncommon species in this recognised hotspot due to site formation, works related land uses (e.g. stock piling, car parks, etc.), flytippings and hillfires. No avoidance or compensation measures are specified in the proponent’s responses (Table 2.7).
2. Habitat of Horseshoe Crab will be lost to the Project. Although there have been no recent official records in the assessment area, past records revealed that the shores of Lung Kwu Tan and Lung Kwu Sheung Tan are their nursery grounds. In view of its conservation status and their occurrence in nearby shores, Survey and mitigation measures should be proposed for this endangered species. However, our concern has not been addressed in the proponent's response table.
3. The assessment of Chinese White Dolphin (CWD) impacts is insufficiently precautionary. Given the critically low and declining population in Northwest Lantau, the permanent loss of ~170 ha of marine habitat should be rated as at least a moderate impact, not "minor". A robust, long-term CWD monitoring and adaptive management plan is required.
Air Quality
4. The pollutant concentration predicted by PATH v3.0 for Years 2028, 2030 and 2035 revealed that "exceedances of 10th highest 8-hr O3 and the peak season O3 concentrations are predicted" (Sec. 3.2.3.4). "O3 is more a regional air pollution problem" may be over-simplified and without any solid evidences. This reckless negligence irresponsibly exposes the public to additional health risk.
5. The Report acknowledged regional O₃ exceedances but dismissed the Project's contribution. An assessment of the Project’s NOx/VOC precursor emissions and a commitment to Best Available Technology (BAT) for all engines must be included.
6. The assessment over-relies on "separation distance" as a primary justification, substituting for detailed quantitative dispersion modelling for fugitive dust from large-scale earthworks. Quantitative air dispersion modelling for peak construction phases should be conducted.
7. Cumulative impacts with other major projects in the NWNT are dismissed based on distance. A qualitative regional cumulative air impact assessment must be provided.
Water Quality
8. Although information regarding the additional pollution loading from the future top-side development is not available at the time of preparing the Report, necessary mitigation should be proposed, executed and in place at current phase to guarantee the validity of the EIA results and avoid jeopardize the effort of proposed mitigation measures.
9. The conclusion that unmitigated impacts would be compliant undermines the necessity of proposed measures. Stringent, real-time performance criteria for silt curtains with explicit contingency plans must be part of the EM&A.
10. The long-term viability of the "green channels" is at high risk of water quality deterioration and eutrophication due to reduced flushing effect. A comprehensive Green Channel Management and Water Quality Plan with long-term monitoring and management responsibility is required, not just 12 months of dissolved oxygen monitoring along the green channels.
11. Moreover, the Environmental Permit must explicitly prohibit any effluent outfalls, stormwater outfalls or wastewater and surface runoff from discharging to water courses and outlets/estuaries of green channels.
12. Cumulative impacts with other major reclamation/dredging projects (e.g., RTT, Sunny Bay) are deferred. A coordinated cumulative water quality impact assessment is essential.
Waste Management & Land Contamination
13. The land contamination assessment is preliminary only. Detailed Site Investigation (SI) and a Contamination Assessment Plan (CAP) must be completed and approved before construction commencement on affected land.
14. The beneficial reuse of dredged sediment lacks a concrete plan. A Sediment Reuse Feasibility Study with clear targets must be required.
15. We agree that all dump trucks/ marine vessels engaged in the Project should be equipped with Global Positioning System (GPS) or equivalent automatic system for real time tracking and monitoring of their travel routings and parking locations to prohibit illegal dumping and landfilling of waste. Therefore, stricter waste transportation tracking and enforcement should be implemented. Mandatory real-time GPS tracking with geofencing for all waste haulage vessels and vehicles, linked to contractual penalties, must be imposed.
Ecology
16. Mitigation for the newly discovered LKST Egretry, located only about 30m from works, should be enhanced with larger buffer zone, construction activity prohibition during the breeding season and a 24-hour disturbance monitoring plan must be implemented.
17. As "the project design has also considered the preservation of the natural watercourse at LKST (FS2) by connecting to the eastern green channel, maintaining the connectivity between FS2 and the nearby marine habitats" (Sec 8.5.1.1), hydraulic, hydrological and water quality parameters should be considered in project design. Buffer zones for natural stream course, especially FS2, should be provided during construction and operation phase because there is highly utilized by different species and they ecologically and hydrologically connect coastal marine habitat to terrestrial habitats.
18. Two Green Channels will be created by adopting eco-shoreline as mitigation measure for marine ecological impacts. To be an effective mitigation measures, the green channels should be established before the commencement of top-side development of the reclamation.
19. The Report highlighted that "the eco-shoreline at Tung Chung East was found to support over 100 different species of marine life, including horseshoe crab at rocky eco-shoreline" (Sec 8.9.5.8). Therefore, recolonization of Horseshoe Crabs is proven feasible and they should NOT be excluded from the ecological mitigation measures and monitoring. However, the Report also mentioned that "Horseshoe crab nursery grounds are characteristically shallow, sheltered intertidal zones with soft sediment" (Sec 8.3.3.10). Suitable substratum should be provided in the eco-shorelines for restoring Horseshoe Crab's nursery ground.
20. In view that eco-shoreline technique is still in its infancy stage in Hong Kong and no local precedent project can be made reference to, ecologists, hydraulic professionals, green groups and other related stakeholders should be consulted for the detailed design of Green Channels regarding:
(a) Identifying their ecological functions that should match the preserved natural shorelines,
(b) Structural dimensions, shape and spatial alignment,
(c) Building materials and construction methods,
(d) Anticipated biotic and abiotic conditions (e.g. proportion and positions of soft and hard substrata) and target species (e.g. Horseshoe Crabs)
(e) The need of plantation, vegetation coverage percentage, planting substratum, plant species selection and long-term management and monitoring,
(f) The need of buffer zones during construction and operation phase.
21. Habitat fragmentation and connectivity impacts are dismissed. A landscape connectivity analysis and measures to maintain terrestrial wildlife corridors are needed.
Landscape & Visual
22. Reliance on future "top-side development" to mitigate the visual impact of the barren reclamation may generate irreversible negative impacts. Mandatory urban design guidelines for the future development must be established now as a permit condition.
In summary, the Report underestimates significant impacts, defers critical mitigation planning, and fails to provide enforceable safeguards for the most sensitive environmental receptors. The Report in its current form is not competent and pre-empt quality EIA for top-side development of the reclamation site. It must be substantially revised to address the fundamental flaws and omissions detailed above before it can be considered for approval.
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
