政策倡議及咨詢

BY EMAIL ONLY
18
 
May
 
2026

Dr. CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)

cc.
Dear Dr. Chui,
就「流浮山、尖鼻咀、白泥一帶的發展」工程項目簡介表達意見(只有英文)
Project Profile for Developments at Lau Fau Shan, Tsim Bei Tsui and Pak Nai Areas

Green Power has reviewed the revised Project Profile (PP) published recently and wishes to reiterate our grave concerns, many of which remain unaddressed. While some of the most damaging elements (e.g., reclamation, dredging, logistics facilities, data centre) have been removed, the Project still poses significant threats to the ecologically irreplaceable Inner Deep Bay wetland system. We offer the following comments on the revised PP; recommendations from our earlier submission that remain valid are retained, and new comments addressing the updated proposal are provided.

General Comments

1. The revised Project now covers a site of approximately 1,160 ha (including part of the Coastal Protection Park, CPP) with a development area of about 410 ha. It would include a road network and developments such as public and private residential housing, business and technology parks, eco-tourism uses, retail, dining and entertainment uses, a revamped seafood market, government institutions (e.g. electricity substation, sewage treatment works, sewage pumping stations, etc.) and education institutions. The Project also comprises part of the CPP (Section 1.4.1).

2. Lau Fau Shan, Tsim Bei Tsui and Pak Nai are integral to the globally important Inner Deep Bay wetland system. In view of the area’s high ecological sensitivity – now further underscored by the PP’s expanded list of recognised conservation sites (including the proposed Hong Kong Wetland Park Expansion Area, the Mai Po Inner Deep Bay Ramsar Site, multiple SSSIs and active egretries) – ecological conservation must be the overarching development principle. No ecological values within or adjacent to the Project area should be compromised. Potential environmental impacts, especially cumulative impacts from the numerous overlapping and neighbouring projects listed in Section 2.3.1, must be thoroughly assessed, avoided and mitigated in the EIA.

3. The PP states that a draft Recommended Outline Development Plan (RODP) has been developed, but the RODP and associated land use plans are still not provided. Without this basic information (location, scale, layout of major works), it remains impossible to identify all potential environmental impacts. We urge the Project proponent to make the RODP and detailed land use plans publicly available before the EIA Study Brief is issued, so that stakeholders can give fully informed input and the credibility and quality of the EIA are enhanced.

Ecology

4. The coast and intertidal mudflat along the Project area continue to support species of high ecological value, including migratory birds, egretries (four active egretries and two ardeid night roosts are now identified in the PP), horseshoe crabs, Eurasian Otter (now explicitly recorded in the PP), seagrass beds and mangroves. These natural wetlands and their adjacent areas must be preserved in their entirety, and the proposed developments should induce neither direct ecological loss nor excessive human disturbances. The PP’s confirmation of Eurasian Otter presence makes a dedicated, thorough otter survey scheme essential to accurately assess and mitigate impacts.

5. Existing backshore habitat and vegetation along the coast of the Project area must be preserved. They are integral parts of the ecology, surface geology and landscape of the natural coast and intertidal mudflat. The EIA must identify the extent, composition and condition of vegetated backshore habitat and independently monitor its fauna and flora. Moreover, backshore vegetation can enhance climate resilience of soft seashore against coastal erosion and storm surges, and improve coastal water quality for intertidal habitat and oyster farms by filtering the contaminated surface runoff.

6. The previous PP (July 2024) listed reclamation and dredging works of more than 1 ha as possible Designated Projects. Those items have now been removed and the PP states that "no marine works including reclamation and dredging works would be anticipated except for some minor modification, maintenance or demolition works at the intertidal areas in view of public safety, navigation, local enhancement etc." While this withdrawal is welcome, any intertidal works – however minor – could still disturb or destroy sensitive coastal habitats such as seagrass beds, horseshoe crab nurseries and mudflats. The EIA must fully assess the nature, extent and ecological consequences of all such works, justify their necessity, and prescribe stringent avoidance and mitigation measures. The integrity of the coastal wetland ecosystem should not be compromised by intertidal works

7. The CPP is now directly included in the Project, and the EIA will cover its design and implementation. The detailed design of the CPP remains unavailable. The CPP must be designed to conserve the entire holistic wetland ecosystem along the Deep Bay shoreline. At minimum, it should form a continuous belt from Tsim Bei Tsui to Pak Nai, encompassing the whole shore from low tide mark to high tide mark and extending seaward to include permanently submerged shallow seabed. Because the CPP now lies within the development boundary, there is a heightened risk that built development will fragment or encroach upon it. The Government must guarantee that the CPP’s extent is ecologically meaningful and legally protected from any future conversion.

8. Engineering works for the CPP should be kept to an absolute minimum. The level of protection and control in the operational CPP must be comparable to that of existing Marine Parks. Only low intensity, compatible human activities should be allowed, backed by strict statutory regulations to deter clam digging, fishing, littering and other damaging behaviours. A robust visitor control plan, based on an environmental carrying capacity assessment, must be formulated.

9. Tin Shui Wai River (the former Tin Shui Wai Nullah) within the Project area (which was out of the Project site in previous PP) forms part of the Deep Bay wetland system and provides foraging grounds for waterbirds. It must be identified as a key ecological sensitive receiver and included in the ecological impact assessment.

10. Ecological connectivity between Mai Po and Castle Peak must be retained to allow the natural movement of wildlife. We strongly oppose the construction of high rise residential or commercial buildings that could block existing avian flight paths of migratory birds and egrets. The EIA must include dedicated flight line surveys (as promised in Section 5.9.8) and demonstrate that all flight corridors are maintained.

11. The alignment of the new road network, including roads for the Smart and Green Mass Transit System and green transport corridor, must avoid any habitat fragmentation. No new public roads or cycle tracks should intrude into or border ecologically sensitive areas, and all necessary crossings must include wildlife friendly under or over passes.

12. Sufficient ecological survey effort must be carried out to establish a robust, up to date baseline. In particular:

— A specific, long term survey scheme for Eurasian Otter (now confirmed present) is required to map distribution, abundance and habitat use.

— The PP has updated the known nursery sites for horseshoe crabs (Chinese Horseshoe Crab at Sheung Pak Nai, Pak Nai and Tsim Bei Tsui; Mangrove Horseshoe Crab at Pak Nai, Sha Kong Tsuen and Tsim Bei Tsui). Detailed field surveys must be conducted in the appropriate seasons to confirm these records and identify any additional nursery grounds, so that all such areas are fully protected.

— Comprehensive intertidal surveys covering mudflats, mangroves and seagrass beds are needed, especially in areas potentially affected by the minor intertidal works or by changes in hydrology and runoff.

Air Quality

13. According to Environmental Protection Department's yearly Air Quality and Health Index (AQHI) data, Tuen Mun and Yuen Long have consistently ranked as the most polluted districts in terms of high health risk hours and days. The Project area lies in close proximity to both.

14. Effective mitigation measures must control all potential air pollution sources to avoid further worsening air quality. The PP now acknowledges potential odour from construction phase sediments (excavated pond and river sediments) and cumulative odour from existing and planned facilities (San Wai STW, the Effluent Polishing Plant, transfer station, etc.). Specific measures to prevent odour nuisance – covering stockpiles, rapid removal, and deodorisation systems – must be mandatory and their effectiveness demonstrated. Furthermore, the EIA should evaluate strategies to suppress ozone formation and health impacts, such as extensive urban greening to lower surface temperatures and strict control of volatile organic compound emissions from any industrial or commercial sources in the Project area.

Water Quality

15. The proposed Project is in close vicinity to the Mai Po Inner Deep Bay Ramsar Site. To comply with the "zero discharge policy" for Deep Bay and protect the ecology of the Ramsar Site, any untreated surface runoff generated from the Project site during both construction and operational phases must be prevented from entering any natural or channelised watercourses that connect to Deep Bay. Mitigation and control measures should be incorporated into the works contract specifications.

16. Natural backshore vegetation must be preserved. It filters and reduces pollutant loads in surface runoff before it reaches the coast and intertidal mudflat, protects mudflats, beaches and seagrass beds from erosion during rainstorms, and helps trap sediment that could otherwise smother sensitive habitats.

17. Backshore vegetation is especially critical given the extensive construction works and long-term urban runoff that will be generated. It is a vital buffer for sensitive habitats such as seagrass beds and horseshoe crab spawning and nursery grounds. Removal of backshore vegetation must be avoided; where already lost, revegetation with native species of equivalent ecological function should be implemented.

18. Robust measures to prevent and respond to accidental chemical spillages must be devised in the EIA. This applies to the construction phase and to the operational phase, particularly for the business/technology parks, the revamped seafood market, and any road networks where hazardous materials may be transported. Although logistics facilities and a data centre have been removed from the PP, the EIA must still assess and mitigate chemical usage and storage in the remaining developments.

Solid Waste

19. As most adjoining areas are rural, fly tipping of solid wastes generated by this Project will be extremely difficult to combat. The Project area is already a known fly tipping blackspot in the Northwest New Territories. Even when incidents are detected, reinstatement is hampered by land ownership and zoning constraints. The PP now mentions floating refuse and the need to manage fishpond sediment. Stricter monitoring and control of waste storage, transportation and disposal are imperative. Mitigation measures to prevent illegal and environmentally destructive dumping, including real time GPS tracking of all waste haulage vehicles (noted in Section 5.5.1), must be made binding in the works contracts and rigorously enforced.

Brownfield Proliferation

20. A proper reallocation and/or compensation plan for the existing brownfield operations in the Project area must be formulated early in the planning process. Without such a plan, brownfield uses will simply shift to nearby rural areas, leading to a proliferation of unregulated and environmentally damaging activities. The EIA should demonstrate how this displacement will be avoided.

Eco-tourism

21. The PP repeatedly emphasises eco-tourism (the proposed CPP, eco-tourism land uses, the revamped seafood market as a tourist attraction, and the proposed HKWP Expansion Area) but provides no definition, strategy or management framework. Eco-tourism is not automatically environmentally benign; poorly planned tourism can severely degrade the very natural assets it purports to celebrate. The EIA must include:

— An ecological carrying capacity assessment for the entire LFS/CPP/HKWP Expansion Area tourism system.

— A science-based monitoring programme for environmental and ecological resources.

— Continuous assessment of the environmental performance of tourism related businesses, activities and facilities.

— A surveillance and control mechanism with clear, enforceable operating conditions.

— Without these, the claimed "eco-tourism" developments must not receive any preferential treatment in the EIA process.

Additional Comments on the Revised Project Profile

22. Expanded Project Boundary and Protection of Recognised Sites

The Project site has grown to 1,160 ha, now partly overlapping with the CPP and directly adjacent to the proposed HKWP Expansion Area. The EIA must unambiguously demarcate "no development" buffers around all recognised conservation sites (Ramsar Site, SSSIs, egretries, etc.) and demonstrate that the proposed development envelope does not result in any direct or indirect impacts on these areas.

23. Digital Technology Hub and Business Parks

The introduction of a "digital technology hub" and business/technology parks replaces the previously proposed logistics facilities and data centre. While potentially less polluting in terms of diesel emissions and dust, these new land uses may still involve hazardous chemicals (e.g., in laboratories, cooling systems) and could generate significant electronic waste. The EIA should assess the full life cycle environmental and waste implications of these facilities.

24. River Enhancement and Revitalisation Works

The revised PP explicitly includes "river enhancement and revitalisation works" (Section 3.1.2). Works in or near watercourses that connect to Deep Bay pose risks to water quality and aquatic ecology. Detailed surveys of all affected watercourses, assessment of ecological and hydrological impacts, and designs that maintain natural stream morphology and ecological continuity must be required.

25. Effluent Polishing Plant and Emergency Discharge

Any treated effluent discharged into Deep Bay must meet the most stringent standards set under the EIAO TM, and contingency measures (dual power supply, adequate storage capacity, bypass mechanisms) must be specified to guarantee absolutely no untreated emergency discharge reaches the Ramsar Site or other sensitive waters. The EIA should also evaluate alternative options, including full reuse of treated effluent for non-potable purposes within the development (which could offset freshwater demand and eliminate marine discharge).

26. Removal of Potentially Damaging Designated Projects

The removal of B.5 (container backup area), C.2 (reclamation >1 ha), C.12 (dredging >500,000 m³), F.4 (water reclamation facility) and N.3 (wholesale fish market) from the list of potential DPs is a positive step. However, the Study Brief and EIA must include a commitment that no reclamation, dredging or container storage will be introduced later through design changes or variations. Any future proposal to include such elements should require a completely new EIA.

27. Population, Employment and Traffic

The planned population (141,000-146,000) and employment (45,000) have changed from the previous PP. The cumulative traffic and noise impacts, especially when combined with the Northern Metropolis Highway and other concurrent road schemes, must be reassessed using the updated figures.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 39610200, F: 2314 2661, Email: info@greenpower.org.hk).

Green Power has reviewed the revised Project Profile (PP) published recently and wishes to reiterate our grave concerns, many of which remain unaddressed. While some of the most damaging elements (e.g., reclamation, dredging, logistics facilities, data centre) have been removed, the Project still poses significant threats to the ecologically irreplaceable Inner Deep Bay wetland system. We offer the following comments on the revised PP; recommendations from our earlier submission that remain valid are retained, and new comments addressing the updated proposal are provided.

General Comments

1. The revised Project now covers a site of approximately 1,160 ha (including part of the Coastal Protection Park, CPP) with a development area of about 410 ha. It would include a road network and developments such as public and private residential housing, business and technology parks, eco-tourism uses, retail, dining and entertainment uses, a revamped seafood market, government institutions (e.g. electricity substation, sewage treatment works, sewage pumping stations, etc.) and education institutions. The Project also comprises part of the CPP (Section 1.4.1).

2. Lau Fau Shan, Tsim Bei Tsui and Pak Nai are integral to the globally important Inner Deep Bay wetland system. In view of the area’s high ecological sensitivity – now further underscored by the PP’s expanded list of recognised conservation sites (including the proposed Hong Kong Wetland Park Expansion Area, the Mai Po Inner Deep Bay Ramsar Site, multiple SSSIs and active egretries) – ecological conservation must be the overarching development principle. No ecological values within or adjacent to the Project area should be compromised. Potential environmental impacts, especially cumulative impacts from the numerous overlapping and neighbouring projects listed in Section 2.3.1, must be thoroughly assessed, avoided and mitigated in the EIA.

3. The PP states that a draft Recommended Outline Development Plan (RODP) has been developed, but the RODP and associated land use plans are still not provided. Without this basic information (location, scale, layout of major works), it remains impossible to identify all potential environmental impacts. We urge the Project proponent to make the RODP and detailed land use plans publicly available before the EIA Study Brief is issued, so that stakeholders can give fully informed input and the credibility and quality of the EIA are enhanced.

Ecology

4. The coast and intertidal mudflat along the Project area continue to support species of high ecological value, including migratory birds, egretries (four active egretries and two ardeid night roosts are now identified in the PP), horseshoe crabs, Eurasian Otter (now explicitly recorded in the PP), seagrass beds and mangroves. These natural wetlands and their adjacent areas must be preserved in their entirety, and the proposed developments should induce neither direct ecological loss nor excessive human disturbances. The PP’s confirmation of Eurasian Otter presence makes a dedicated, thorough otter survey scheme essential to accurately assess and mitigate impacts.

5. Existing backshore habitat and vegetation along the coast of the Project area must be preserved. They are integral parts of the ecology, surface geology and landscape of the natural coast and intertidal mudflat. The EIA must identify the extent, composition and condition of vegetated backshore habitat and independently monitor its fauna and flora. Moreover, backshore vegetation can enhance climate resilience of soft seashore against coastal erosion and storm surges, and improve coastal water quality for intertidal habitat and oyster farms by filtering the contaminated surface runoff.

6. The previous PP (July 2024) listed reclamation and dredging works of more than 1 ha as possible Designated Projects. Those items have now been removed and the PP states that "no marine works including reclamation and dredging works would be anticipated except for some minor modification, maintenance or demolition works at the intertidal areas in view of public safety, navigation, local enhancement etc." While this withdrawal is welcome, any intertidal works – however minor – could still disturb or destroy sensitive coastal habitats such as seagrass beds, horseshoe crab nurseries and mudflats. The EIA must fully assess the nature, extent and ecological consequences of all such works, justify their necessity, and prescribe stringent avoidance and mitigation measures. The integrity of the coastal wetland ecosystem should not be compromised by intertidal works

7. The CPP is now directly included in the Project, and the EIA will cover its design and implementation. The detailed design of the CPP remains unavailable. The CPP must be designed to conserve the entire holistic wetland ecosystem along the Deep Bay shoreline. At minimum, it should form a continuous belt from Tsim Bei Tsui to Pak Nai, encompassing the whole shore from low tide mark to high tide mark and extending seaward to include permanently submerged shallow seabed. Because the CPP now lies within the development boundary, there is a heightened risk that built development will fragment or encroach upon it. The Government must guarantee that the CPP’s extent is ecologically meaningful and legally protected from any future conversion.

8. Engineering works for the CPP should be kept to an absolute minimum. The level of protection and control in the operational CPP must be comparable to that of existing Marine Parks. Only low intensity, compatible human activities should be allowed, backed by strict statutory regulations to deter clam digging, fishing, littering and other damaging behaviours. A robust visitor control plan, based on an environmental carrying capacity assessment, must be formulated.

9. Tin Shui Wai River (the former Tin Shui Wai Nullah) within the Project area (which was out of the Project site in previous PP) forms part of the Deep Bay wetland system and provides foraging grounds for waterbirds. It must be identified as a key ecological sensitive receiver and included in the ecological impact assessment.

10. Ecological connectivity between Mai Po and Castle Peak must be retained to allow the natural movement of wildlife. We strongly oppose the construction of high rise residential or commercial buildings that could block existing avian flight paths of migratory birds and egrets. The EIA must include dedicated flight line surveys (as promised in Section 5.9.8) and demonstrate that all flight corridors are maintained.

11. The alignment of the new road network, including roads for the Smart and Green Mass Transit System and green transport corridor, must avoid any habitat fragmentation. No new public roads or cycle tracks should intrude into or border ecologically sensitive areas, and all necessary crossings must include wildlife friendly under or over passes.

12. Sufficient ecological survey effort must be carried out to establish a robust, up to date baseline. In particular:

— A specific, long term survey scheme for Eurasian Otter (now confirmed present) is required to map distribution, abundance and habitat use.

— The PP has updated the known nursery sites for horseshoe crabs (Chinese Horseshoe Crab at Sheung Pak Nai, Pak Nai and Tsim Bei Tsui; Mangrove Horseshoe Crab at Pak Nai, Sha Kong Tsuen and Tsim Bei Tsui). Detailed field surveys must be conducted in the appropriate seasons to confirm these records and identify any additional nursery grounds, so that all such areas are fully protected.

— Comprehensive intertidal surveys covering mudflats, mangroves and seagrass beds are needed, especially in areas potentially affected by the minor intertidal works or by changes in hydrology and runoff.

Air Quality

13. According to Environmental Protection Department's yearly Air Quality and Health Index (AQHI) data, Tuen Mun and Yuen Long have consistently ranked as the most polluted districts in terms of high health risk hours and days. The Project area lies in close proximity to both.

14. Effective mitigation measures must control all potential air pollution sources to avoid further worsening air quality. The PP now acknowledges potential odour from construction phase sediments (excavated pond and river sediments) and cumulative odour from existing and planned facilities (San Wai STW, the Effluent Polishing Plant, transfer station, etc.). Specific measures to prevent odour nuisance – covering stockpiles, rapid removal, and deodorisation systems – must be mandatory and their effectiveness demonstrated. Furthermore, the EIA should evaluate strategies to suppress ozone formation and health impacts, such as extensive urban greening to lower surface temperatures and strict control of volatile organic compound emissions from any industrial or commercial sources in the Project area.

Water Quality

15. The proposed Project is in close vicinity to the Mai Po Inner Deep Bay Ramsar Site. To comply with the "zero discharge policy" for Deep Bay and protect the ecology of the Ramsar Site, any untreated surface runoff generated from the Project site during both construction and operational phases must be prevented from entering any natural or channelised watercourses that connect to Deep Bay. Mitigation and control measures should be incorporated into the works contract specifications.

16. Natural backshore vegetation must be preserved. It filters and reduces pollutant loads in surface runoff before it reaches the coast and intertidal mudflat, protects mudflats, beaches and seagrass beds from erosion during rainstorms, and helps trap sediment that could otherwise smother sensitive habitats.

17. Backshore vegetation is especially critical given the extensive construction works and long-term urban runoff that will be generated. It is a vital buffer for sensitive habitats such as seagrass beds and horseshoe crab spawning and nursery grounds. Removal of backshore vegetation must be avoided; where already lost, revegetation with native species of equivalent ecological function should be implemented.

18. Robust measures to prevent and respond to accidental chemical spillages must be devised in the EIA. This applies to the construction phase and to the operational phase, particularly for the business/technology parks, the revamped seafood market, and any road networks where hazardous materials may be transported. Although logistics facilities and a data centre have been removed from the PP, the EIA must still assess and mitigate chemical usage and storage in the remaining developments.

Solid Waste

19. As most adjoining areas are rural, fly tipping of solid wastes generated by this Project will be extremely difficult to combat. The Project area is already a known fly tipping blackspot in the Northwest New Territories. Even when incidents are detected, reinstatement is hampered by land ownership and zoning constraints. The PP now mentions floating refuse and the need to manage fishpond sediment. Stricter monitoring and control of waste storage, transportation and disposal are imperative. Mitigation measures to prevent illegal and environmentally destructive dumping, including real time GPS tracking of all waste haulage vehicles (noted in Section 5.5.1), must be made binding in the works contracts and rigorously enforced.

Brownfield Proliferation

20. A proper reallocation and/or compensation plan for the existing brownfield operations in the Project area must be formulated early in the planning process. Without such a plan, brownfield uses will simply shift to nearby rural areas, leading to a proliferation of unregulated and environmentally damaging activities. The EIA should demonstrate how this displacement will be avoided.

Eco-tourism

21. The PP repeatedly emphasises eco-tourism (the proposed CPP, eco-tourism land uses, the revamped seafood market as a tourist attraction, and the proposed HKWP Expansion Area) but provides no definition, strategy or management framework. Eco-tourism is not automatically environmentally benign; poorly planned tourism can severely degrade the very natural assets it purports to celebrate. The EIA must include:

— An ecological carrying capacity assessment for the entire LFS/CPP/HKWP Expansion Area tourism system.

— A science-based monitoring programme for environmental and ecological resources.

— Continuous assessment of the environmental performance of tourism related businesses, activities and facilities.

— A surveillance and control mechanism with clear, enforceable operating conditions.

— Without these, the claimed "eco-tourism" developments must not receive any preferential treatment in the EIA process.

Additional Comments on the Revised Project Profile

22. Expanded Project Boundary and Protection of Recognised Sites

The Project site has grown to 1,160 ha, now partly overlapping with the CPP and directly adjacent to the proposed HKWP Expansion Area. The EIA must unambiguously demarcate "no development" buffers around all recognised conservation sites (Ramsar Site, SSSIs, egretries, etc.) and demonstrate that the proposed development envelope does not result in any direct or indirect impacts on these areas.

23. Digital Technology Hub and Business Parks

The introduction of a "digital technology hub" and business/technology parks replaces the previously proposed logistics facilities and data centre. While potentially less polluting in terms of diesel emissions and dust, these new land uses may still involve hazardous chemicals (e.g., in laboratories, cooling systems) and could generate significant electronic waste. The EIA should assess the full life cycle environmental and waste implications of these facilities.

24. River Enhancement and Revitalisation Works

The revised PP explicitly includes "river enhancement and revitalisation works" (Section 3.1.2). Works in or near watercourses that connect to Deep Bay pose risks to water quality and aquatic ecology. Detailed surveys of all affected watercourses, assessment of ecological and hydrological impacts, and designs that maintain natural stream morphology and ecological continuity must be required.

25. Effluent Polishing Plant and Emergency Discharge

Any treated effluent discharged into Deep Bay must meet the most stringent standards set under the EIAO TM, and contingency measures (dual power supply, adequate storage capacity, bypass mechanisms) must be specified to guarantee absolutely no untreated emergency discharge reaches the Ramsar Site or other sensitive waters. The EIA should also evaluate alternative options, including full reuse of treated effluent for non-potable purposes within the development (which could offset freshwater demand and eliminate marine discharge).

26. Removal of Potentially Damaging Designated Projects

The removal of B.5 (container backup area), C.2 (reclamation >1 ha), C.12 (dredging >500,000 m³), F.4 (water reclamation facility) and N.3 (wholesale fish market) from the list of potential DPs is a positive step. However, the Study Brief and EIA must include a commitment that no reclamation, dredging or container storage will be introduced later through design changes or variations. Any future proposal to include such elements should require a completely new EIA.

27. Population, Employment and Traffic

The planned population (141,000-146,000) and employment (45,000) have changed from the previous PP. The cumulative traffic and noise impacts, especially when combined with the Northern Metropolis Highway and other concurrent road schemes, must be reassessed using the updated figures.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 39610200, F: 2314 2661, Email: info@greenpower.org.hk).

Yours faithfully,

LO Wing-fung
Environmental Affairs Manager
Green Power

Yours faithfully,

LO Wing-fung
Environmental Affairs Manager
Green Power

二零二六年
五月
十八日