May 2023

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

Dear Dr. Chui,
就「將軍澳第137區及相關填海用地的發展」工程項目簡介表達意見 (只有英文)
Project Profile for Development of Tseung Kwan O Area 137 and Associated Reclamation Sites

Green Power would like to draw your kind attention to our comments about the above-captioned Project Profile (PP).

1. Sea reclamation is highly destructive to the environment because of the permanent loss of marine habitat that has no way to compensate. Hence, according to the “avoidance” principle, the project proponent should thoughtfully consider all alternatives (including but not limited to the proposed cavern development as mentioned in Section 1.4.11) in the EIA process and make justification upon the final development option.

2. Besides, in view of the “minimizing” principle, the scale of the proposed sea reclamation (if necessary) should be minimized as far as possible. We especially highlight the needs to preserve the only remaining natural coastline along the TKO Area 132, which is also currently the most continuous one in the Junk Bay. However, the proposed reclamation work is expected to heavily ruin the coastal landscape.

3. The “Study Area Boundary” drawn in dotted line in the preliminary Outline Development Plan (Figure- Plan 1) does not indicate a meaningful assessment area. We urge the project proponent to clearly define the formal EIA study area with a 500m zone surrounding the proposed project site boundaries, the potential environmental impacts within that area should be fully assessed.

4. All the sea reclamation works (if necessary) should be conducted in a non-dredge way and enclosed by silt curtain to minimize the water quality and ecological impacts.

5. Habitat loss in Clearwater Bay Country Park and Fat Tong Chau is anticipated (Section 3.9.2) whereas no compensation has been proposed in the PP. Apart from the mitigation measures for the species of conservation importance (Section 5.9.1), ecological impacts due to vegetation clearance should also be mitigated by ex-situ compensatory planting.

6. Since mitigation measures for natural terrain hazard will be conducted in the Clearwater Bay Country Park (Section 3.9.2), the associated supporting facilities (e.g. stockpiling areas, worker station etc.) should be established away from the Country Park area as far as practicable to reduce the footprints and human disturbances.

7. Construction and demolition (C&D) materials, chemical wastes, dredged sediments, refuse etc. should be properly stored, transported, and finally disposed of at the designated facilities and/or environmentally treated. Unauthorized disposal of solid waste should be strictly prohibited and deterrent clauses should be incorporated in the work contracts to monitor and penalize any fly-tipping activities.

8. A few hazardous facilities are in operation in the vicinity of the proposed project, a comprehensive hazard assessment should be conducted to identify and cope with any potential risks. Emergency evacuation protocol should be formulated in response to unexpected incidents.

9. The odour impact induced by the proposed refuse transfer station and marine refuse collection point during the operational phase should be assessed and mitigated by effective measures.

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