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 and comments regarding the Project Profile (PP) for the South Island Line (West) (the Project). We would like to highlight several critical environmental issues that need to be addressed or are omitted during the Environmental Impact Assessment (EIA) process.
Introduction
1. The Project is a new transit line, located in the southern and western part of Hong Kong Island, using Smart Green Mass Transit System (SGMTS) with the preliminary alignment starting at the existing Wong Chuk Hang Station of South Island Line (East) and ending at HKU Station of Island Line.
2. All the proposed stations, and depot locations, alignments and project boundaries are subject to change. Ancillary facilities such as Ventilation Buildings (VBs), Emergency Access Points (EAPs) / Emergency Egress Points (EEPs), other station associated facilities, system-wide facilities and stations pedestrian linkage facilities and associated road works are tentative and subject to change in the detailed planning and design of the Project.
General Comments
3. In view of engineering feasibility and associated EIA, basic key information, including planned passenger capacity, approximate area of the depot, size of carriages, etc, are lacking in this PP except the preliminary alignment and six intermediate stations.
4. Without such basic information, it is unfair for the public to participate in consultation process under EIAO because solid comments cannot be lodged when most aspects of the Project are vague. For example, the scale, spatial and temporal impacts and environment/ecological spillover effects cannot be identified, assessed and quantified in a meaningful manner.
5. More importantly, an adequate Study Brief (under EIAO) cannot be formulated and consequently competent EIA cannot be conducted properly that jeopardizes the statutory EIA process. Therefore, a more detailed PP with basic engineering and transportation parameters and information should be provided for public inspection and applying for a competent Study Brief.
Transit System
6. While the Project adopts a medium-capacity SGMTS, the specific technology remains to be confirmed. The options of system types should be definitively stated to allow a basic assessment of its environmental impacts. The options should also include different considerations of route alignment, locations of ancillary facilities mentioned in Point 2.
7. The "green" claims, such as being more environmentally sustainable and energy-efficient, are currently described qualitatively. Without the scale of passenger capacity and adopted system type, these benefits cannot be validated with projected metrics for CO2-equivalent reduction and other pollutant reductions compared to a "without project" scenario.
8. As the system types remained unknown, potential issues may be omitted such as the management and disposal of batteries or power storage systems for electric transit vehicles, if adopted, and potential electromagnetic fields from power systems.
Air Quality
9. Construction activities will involve tunneling works potentially using the drill and blast method that will generate significant dust and emissions. The impacts of this works have not been specified in the PP.
10. Odour impacts have not been properly addressed such as potential odour impacts from dredging or seabed levelling for the temporary barging point at Tin Wan Praya Road.
Noise
11. Pre-construction baseline vibration measurements at sensitive receivers near the tunnel section is neglected in the PP to ensure groundborne noise remains within acceptable limits during construction phase.
Water Quality
12. The potential impacts of proposed barging point and associated dredging works at Tin Wan Praya Road pose a risk to coastal water quality have not been specified in the PP.
13. There is a natural stream flowing from west of Sai Kwok Tai Wong Temple (西國大王廟) to Waterfall Bay which is obviously near to the proposed location of depot. However, it is not listed as Water Sensitive Receiver in the PP.
Waste Management
14. Control of dump trucks through trip-ticket system to prevent illegal dumping or fly-tipping is not efficient and effective if dumping involves private lands or part of C&D waste is replaced by other refuse during the transfer. More effective and efficient surveillance measures such as GPS tracking have not been proposed in the PP, with featuring alarm and penalty systems to deter illegal dumping and fly-tipping. Penalty terms for deviation from designated routes should be explicitly listed in contracts.
Ecology
15. The alignment will pass through the Compensatory Ecological Planting Area (EPA) under South Island Line (East) Project at Staunton Creek Nullah, a known ardeid roosting site. The PP sets a bad precedent to encroach or occupy stipulated mitigation habitats of previous approved projects under EIAO.
16. The conclusion that Wong Chuk Hang Egretry and Ap Lei Chau Ardeid Night Roost will not be impacted is too reckless without any scientific support such as flight line survey.
17. Issue of bird collision with noise barriers/canopies and vehicle is omitted in the PP. Marine and freshwater ecological impact assessment have not been proposed to address any potential impacts caused by the Project.
18. Regarding the tunnel section passing underneath the Lung Fu Shan Country Park, hydrological and hydraulic impacts on the streams flowing on slopes surface above the alignment have not been addressed in the PP, e.g. natural stream discharge drawdown due to underground water leakage in the tunnel during both construction and operation phase.
Hazard to Life
19. The slopes where the tunnel section passing underneath are steep and deposited with colluvium. The vibration induced by the drill and blast works may elevate the risk of mass movement (landslide) and threaten the residential area around Pokfulam Road Playground. The issue has been neglected in the PP.
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 and comments regarding the Project Profile (PP) for the South Island Line (West) (the Project). We would like to highlight several critical environmental issues that need to be addressed or are omitted during the Environmental Impact Assessment (EIA) process.
Introduction
1. The Project is a new transit line, located in the southern and western part of Hong Kong Island, using Smart Green Mass Transit System (SGMTS) with the preliminary alignment starting at the existing Wong Chuk Hang Station of South Island Line (East) and ending at HKU Station of Island Line.
2. All the proposed stations, and depot locations, alignments and project boundaries are subject to change. Ancillary facilities such as Ventilation Buildings (VBs), Emergency Access Points (EAPs) / Emergency Egress Points (EEPs), other station associated facilities, system-wide facilities and stations pedestrian linkage facilities and associated road works are tentative and subject to change in the detailed planning and design of the Project.
General Comments
3. In view of engineering feasibility and associated EIA, basic key information, including planned passenger capacity, approximate area of the depot, size of carriages, etc, are lacking in this PP except the preliminary alignment and six intermediate stations.
4. Without such basic information, it is unfair for the public to participate in consultation process under EIAO because solid comments cannot be lodged when most aspects of the Project are vague. For example, the scale, spatial and temporal impacts and environment/ecological spillover effects cannot be identified, assessed and quantified in a meaningful manner.
5. More importantly, an adequate Study Brief (under EIAO) cannot be formulated and consequently competent EIA cannot be conducted properly that jeopardizes the statutory EIA process. Therefore, a more detailed PP with basic engineering and transportation parameters and information should be provided for public inspection and applying for a competent Study Brief.
Transit System
6. While the Project adopts a medium-capacity SGMTS, the specific technology remains to be confirmed. The options of system types should be definitively stated to allow a basic assessment of its environmental impacts. The options should also include different considerations of route alignment, locations of ancillary facilities mentioned in Point 2.
7. The "green" claims, such as being more environmentally sustainable and energy-efficient, are currently described qualitatively. Without the scale of passenger capacity and adopted system type, these benefits cannot be validated with projected metrics for CO2-equivalent reduction and other pollutant reductions compared to a "without project" scenario.
8. As the system types remained unknown, potential issues may be omitted such as the management and disposal of batteries or power storage systems for electric transit vehicles, if adopted, and potential electromagnetic fields from power systems.
Air Quality
9. Construction activities will involve tunneling works potentially using the drill and blast method that will generate significant dust and emissions. The impacts of this works have not been specified in the PP.
10. Odour impacts have not been properly addressed such as potential odour impacts from dredging or seabed levelling for the temporary barging point at Tin Wan Praya Road.
Noise
11. Pre-construction baseline vibration measurements at sensitive receivers near the tunnel section is neglected in the PP to ensure groundborne noise remains within acceptable limits during construction phase.
Water Quality
12. The potential impacts of proposed barging point and associated dredging works at Tin Wan Praya Road pose a risk to coastal water quality have not been specified in the PP.
13. There is a natural stream flowing from west of Sai Kwok Tai Wong Temple (西國大王廟) to Waterfall Bay which is obviously near to the proposed location of depot. However, it is not listed as Water Sensitive Receiver in the PP.
Waste Management
14. Control of dump trucks through trip-ticket system to prevent illegal dumping or fly-tipping is not efficient and effective if dumping involves private lands or part of C&D waste is replaced by other refuse during the transfer. More effective and efficient surveillance measures such as GPS tracking have not been proposed in the PP, with featuring alarm and penalty systems to deter illegal dumping and fly-tipping. Penalty terms for deviation from designated routes should be explicitly listed in contracts.
Ecology
15. The alignment will pass through the Compensatory Ecological Planting Area (EPA) under South Island Line (East) Project at Staunton Creek Nullah, a known ardeid roosting site. The PP sets a bad precedent to encroach or occupy stipulated mitigation habitats of previous approved projects under EIAO.
16. The conclusion that Wong Chuk Hang Egretry and Ap Lei Chau Ardeid Night Roost will not be impacted is too reckless without any scientific support such as flight line survey.
17. Issue of bird collision with noise barriers/canopies and vehicle is omitted in the PP. Marine and freshwater ecological impact assessment have not been proposed to address any potential impacts caused by the Project.
18. Regarding the tunnel section passing underneath the Lung Fu Shan Country Park, hydrological and hydraulic impacts on the streams flowing on slopes surface above the alignment have not been addressed in the PP, e.g. natural stream discharge drawdown due to underground water leakage in the tunnel during both construction and operation phase.
Hazard to Life
19. The slopes where the tunnel section passing underneath are steep and deposited with colluvium. The vibration induced by the drill and blast works may elevate the risk of mass movement (landslide) and threaten the residential area around Pokfulam Road Playground. The issue has been neglected in the PP.
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
