May 2023

Dr. CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department

Dear Dr. Chui,
就「元朗攸壆路簡約公屋」工程項目簡介表達意見 (只有英文)
Project Profile for Light Public Housing at Yau Pok Road, Yuen Long

Green Power would like to draw your kind attention to our concerns about the above-captioned project profile.

1. The statutory application for permission (Application No. A/YL-MP/341) for the captioned residential development under the Section 16 of Town Planning Ordinance is still under progress. It is undesirable to start an EIA procedure without incorporating the final decision and conditions made by the Town Planning Board.

2. The Northern Portion of the proposed project falls within the Wetland Buffer Area (WBA) and adjacent to the Wetland Conservation Area (WCA) of the Deep Bay Area that serves an ecological function to protect the globally important wetland — the Mai Po Ramsar site. The Project Site is hence part of the holistic wetland system of outstanding ecological values. In this view, the environmental impacts induced by the proposed project should be thoughtfully assessed and mitigated.

3. However, the EIA results (EIAO Register No. AEIAR-182/2014 approved in 2014) adopted in the current application for direct Environmental Permit are considered to be incomparable and invalid. First, the scale of the captioned project has been largely uplifted. In that previously approved EIA, no residential development is anticipated inside the more ecologically sensitive WBA; the number of building block and the estimated residential population increase is just about one-twenty (106 compared to 2,150) and one-nineteen (287 compared to 5,500) of the captioned project respectively. Second, habitat change in the Ngau Tam Mei Drainage Channel (NTMDC) from highly exposed to shaded is prominent in the past few years as indicated by the notably increase of vegetation density along the riverbank (refer to the aerial photo comparison in Figure 1), the validity of the EcoIA started more than ten years ago is questionable and the corresponding mitigation measures may no longer sufficient to the current ecological status.

Figure 1. Aerial photoof the project site taken in 2018 (left) and 2022 (right)
(Source:Google Earth Pro)

4. Although other relevant ecological survey data has been considered, the 18-month ecological survey conducted in 2019/20 has been questioned by the Town Planning Board and the 1-day reconnaissance survey conducted in December 2022 is not representative at all. Given that high level of usage by wintering birds, including species of conservation values (e.g. up to 47 individuals of Black-faced Spoonbill), is obtained in the NTMDC, and the Yau Pok Road will be the only access to the captioned project during the operational phase, we are afraid that environmental impacts to the NTMDC due to the anticipated increase in human disturbances have been underestimated.

5. During the construction phase,  the  fishponds,  wetlands and farmlands in vicinity are vulnerable to illegal dumping of soil debris and construction and demolish wastes. Regrettably, existing enforcement measures to prevent illegal dumping are ineffective and successful prosecutions are rare. Most importantly, destroyed wetland habitats are difficult to reinstate. Measures to combat fly-tipping problem, such as the real time tracking and monitoring system mentioned in the Project Profile, should be incorporated with deterrent clauses.

6. The Project Site is adjacent to NTMDC which flows into Deep Bay and Ramsar Site. Effluent from the proposed development will directly increase the pollution loading of Deep Bay with pollutants such as vehicle fuel and lubricating oil, fertilizers and pesticides. The Zero Discharge Policy to protect the ecology of Ramsar Site should not be breached.

7. In view of the foreseeable rise in sea level and increased flood risk brought about by climate change, the proposed development should neither weaken the climate resilience of Deep Bay Area nor impose flood risk in the Project Site and neighboring areas.

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

Yours faithfully,

LO Wing-fung
Senior Education & Conservation Officer
Green Power

Yours faithfully,

LO Wing-fung
Senior Education & Conservation Officer
Green Power