政策倡議及咨詢

Green Power would like to draw your kind attention to our grave concerns and recommendations regarding the Environmental Impact Assessment (EIA) Report for the Water Recreation and Yacht Bay Development (the Project). While we acknowledge the Project's goal to bolster Hong Kong's aviation hub status, the massive scale of approximately 218 hectares and the provision of over 500 berths may pose significant, irreversible threats to the sensitive marine and coastal ecology of North Lantau.

We previously submitted detailed comments on the Project Profile (PP-677/2024) on 2 January 2025. Having reviewed the EIA Report and the project proponent's responses in Table 2.15 and Table 2.16, we regret that several key concerns remain unresolved. We would like to highlight the following critical issues:

Key Concerns

1. Green Power would like to re-iterate and raise your attention to our concerned key issues related to the Project:

(a) the Project should not impose adverse impacts on the ecology, water quality, hydrology and environment of Tai Ho Bay and Tung Chung Bay to which the natural river mouths of Tai O Stream and Tung Chung River feed respectively and high biodiversity of flora and fauna are found at both sites.

(b) the Project should not impose adverse impacts on the ecology, water quality, hydrology and environment of Tung Chung EIS and its river basin in Tung Chung West.

(c) the Project should not trigger any environmental and ecological vandalism on North Lantau shores, marine environment, especially the proposed and designated Marine Parks, and rural and natural habitats on Lantau.

Hydraulic Impacts to Ecologically Important Coastal Habitats

2. After completion of the breakwaters, the water flow pattern in the vicinity of the Project will be permanently altered. The hydrodynamic modelling results reveal that the provision of berthing facilities and construction of breakwaters may reduce monthly tidal flow volume by up to 10.7% during flood tides for the three cross-sections near Tung Chung Bay (Table 5.30, Sec. 5.5.6.3).

3. Ignoring indirect impacts (such as sediment transport and altered tidal flushing) due to "no details on the project scale and work method / progress is available" (Sec 5.4.3.8) for concurrent reclamation projects during construction phase, or by stating the project "does not encroach" (Sec. 7.3.3.12) on these areas may underestimate any potential impacts which are irreversible and not restoreable. We recommend a further assessment and hydrodynamic and ecological monitoring focusing specifically on these sensitive receivers (including marine parks) during both construction and operation phase.

4. Moreover, alternation of hydrodynamics may affect the current velocity and/flushing effect that water quality deterioration may occur at Tung Chung River cum Bay and the Tai Ho Stream SSSI, as reveled by the hydrodynamic modelling.

Waste Management and Prevention of Eco-vandalism

5. The EIA proposes GPS tracking but fails to incorporate "no-go" areas (e.g., CPA/CA zones and the planned River Park) with instantaneous alarms. We reiterate that all dump trucks and barges must be equipped with real-time GPS tracking, with “no-go” areas strictly enforced through contractual penalty clauses.

6. It is recommended to include areas west and south of Tung Chung urban town as "no-go" areas to protect mangroves in "CPA" zones, riparian areas in "CA" zones and planned River Park area. An instantaneous alarm system should be utilised that dump trucks will trigger the alarm system when they encroach these no-go areas.

7. In order to protect the ecosystem and natural environment of Tung Chung River Valley cum Bay and South Lantau from air pollution and illegal dumping, large vehicles, construction / dump trucks and similar machineries associated with the Project must be prohibited from entering the section of Tung Chung Road between Ha Ling Pei and Shek Mun Kap, and all sections of South Lantau Road, as well as Chung Mun Road and section of Yu Tung Road to the west of Chung Yan Road. Vehicles that have justified reasons for entering need to seek formal approval from relevant authorities and be closely monitored with GPS devices.

8. The fly-tipping control measures, including but not limited to the above-mentioned "no-go" areas, GPS system and alarm system to control tracks of vehicles and vessels should be implemented with deterrent clauses incorporated in the works contracts. Stringent documentation, verification and monitoring should be implemented.

Water Quality and Chemical Contamination

9. In operation phase, the marine vessels and coastal facilities and structures of the Project will contain antifouling agents/paints which will leach or flank off in the water. These chemicals are toxic in low concentration to many marine life and shellfish. In view of large fleet of vessels berthed in the Project site which is near to coastal ecologically important sites (i.e. Tai Ho Stream SSSI, San Tau SSSI, Tung Chung Bay), the leached/flaked off antifouling agents/paints will affect the survival of marine and coastal wildlife that a comprehensive ecotoxicity assessment should be conducted including foreign vessels. On the other hand, water quality impact of antifouling agents/paints to the users of the Water Park should also be assessed.

10. The active ingredients of watersport sunscreens contain a variety of chemicals including benzophenones which are toxic to marine life. In view of the large number of users of water wake park and inflatable water park, their consumption of sunscreens will contaminate the surrounding water of the Project site in operation phase. Proper assessments and proactive preventive measures (such as on-site provision and mandatory use of ecologically acceptable sunscreen) should be conducted and implemented to avoid water quality pollution with sunscreens' chemicals by water wake park and inflatable water park users and yacht passengers.

11. The Accidental Spillage Prevention and Response Plan must be approved prior to the issuance of the Environmental Permit (EP), rather than during the detailed design phase.

Ecology and Marine Biodiversity

12. Although sightings of Chinese White Dolphins (CWD) are currently low, construction noise and increased traffic represent a significant disturbance. Feasible protective measures should be implemented to avoid further worsening of current situation. Extending Passive Acoustic Monitoring (PAM) beyond 10 months into the operational phase is recommended.

13. The EM&A Manual must include a specific monitoring protocol and a Bird Collision Prevention Plan for glass walls, with post-occupancy monitoring for at least two years.

14. The EIA lacks detailed design specifications for eco-enhanced blocks and success criteria. An Ecoshoreline Implementation Plan with measurable ecological targets must be submitted prior to construction.

Preventing Brownfield Proliferation and Seashore Eco-vandalism

15. In order to avoid triggering uncontrollable development pressures on Lantau, especially Northeast Lantau, Tung Chung West, Tai Ho and natural coastlines, 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 (i.e. areas west of Shun Tung Road, Tung Chung), Pak Mong, Ngau Kwu Long, Tai Ho, Tai Ho Wan, Yam 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.

16. This explicit measures for protecting shores against vandalism associated with the Project is definitely required because there has been a vandalism incident that the sand materials was excavated on the shore of Sha Lo Wan, North Lanatau for the construction of Hong Kong - Zhuhai - Macao Bridge (HZMB) Project on 11 May 2014 (Log Ref.: Com-2014-05-001) ¹.

Climate Resilience

17. As the Project structures are located in highly exposed coastal areas, they are vulnerable to extreme weather and sea-level rise. The design of floating pontoons and breakwaters must be verified against climate projections to prevent structural failures that could result in marine refuse.

18. Preventive measures for fuel/chemical spillages and breaking moorings incidents must be formulated for extreme weather conditions under invasion of super typhoons.

Conclusion

Green Power believes the current EIA Report requires significantly more stringency, especially regarding protection of Tung Chung River basin cum Bay and Tai Ho Stream SSSI, legally binding "no-go" zones with GPS alarms, and prevention of brownfield proliferation on Lantau.

Thank you for your attention to these matters. We trust that these comments will be taken into consideration in the further processing of the EIA Report. For any inquiries, please contact the undersigned (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk) at Green Power.

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