September 2023

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

Dear Dr. Chui,
Green Power’s comments on the EIA Report of Airport Tung Chung Link Project (EIA-295/2023)

Green Power would like to draw your kind attention to our views and comments about the above-captioned EIA Report.

Key Concerns

1. Green Power is particularly concerned about some key issues related to the above-captioned project (the Project):

(a) the Project should not impose adverse impacts on the ecology, water quality, hydrology and environment of Tung Chung Bay to which Tung Chung River’s natural river mouth feeds and at which high biodiversity of flora and fauna are found.

(b) the Project should not impose adverse impacts on the ecology, water quality, hydrology and environment of Tung Chung River 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.

Waste Disposal and Prevention of Eco-vandalism

2. We support the tracking and monitoring of vehicle routes through GPS systems, and opine that control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles from engaging in illegal dumping activities.

3. The estimated amount of waste generated from the Project would include 21,379m3 of inert C&D materials, 1,950 m3 of non-inert C&D materials, 2,803m3 of land-based and marine-based sediment, less than 100 litres per month of chemical waste, 198 tonnes of general refuse, as well as 3m3 per year of floating refuse.

4. However, the amounts of waste to be reused include only 5,963 m3 of inert C&D material and 375 m3 of land-based sediment for on-site backfilling while the waste to be recycled include only 450 m3 of non-inert C&D material, 9 tonnes of general refuse and 1 m3 per year of floating refuse. Thus, there will be large amount of C&D materials and sediment generated from the Project which will lead to eco-vandalism with flytipping and illegal dumping.

5. Flytipping of C&D waste occurs from time to time that threaten the ecologically significant and vulnerable Tung Chung River cum Bay and its river basin. The southern part of the Project site is not far from Tung Chung West rural area and Tung Chung Bay. Although it is mentioned in Chapter 6 that a GPS or equivalent system will be implemented to monitor dump trucks, it is recommended to include areas 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 area.

6. 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 (e.g. using GPS devices).

7. The fly-tipping control measures, including but not limited to the above-mentioned “no-go” areas, GPS system and alarm system to control vehicles’ tracks should be implemented with deterrent clauses incorporated in the works contract. Stringent documentation, verification and monitoring should be implemented.

Aquatic biodiversity, fisheries and water quality

8. Although the EIA report stated that any anticipated water pollution impacts could be avoided if the Best Management Practices (BMPs) are implemented, total elimination of sewage discharged from construction sites is rarely seen in practice. Pollutant generating activities, especially the marine construction works, require implementation and close monitoring with due diligence to protect the water quality of the nearby marine area, especially for the ecologically important Tung Chung Bay where large area of mangrove, seagrass and mudflat located.

9. In order to conserve the ecology and water quality of Tung Chung River Valley cum Bay, the proposed works of the Project should have no association, direct or indirect, to any lands and activities in Tung Chung West, i.e. areas to the west of Chung Yan Road and its connected northern section of Tung Chung Road, where numbers of conservation works are being or will be soon implemented under the Tung Chung New Town Extension Project, e.g. River Park.

10. Any bare soil surfaces and temporarily stored loose materials should be covered and checked especially when rainstorms are anticipated, and kept away from rainfall or runoff. All sediment removal facilities should be adequately designed, checked and cleared to maintain sufficient removal capacity. Adequate barriers, such as silt curtains and perimeter channels should be provided to intercept all sewage or pollutants generated from the land-based work sites.

11. In order to avoid damage to ecology and deterioration of water quality of Tung Chung Bay and mouth of Tung Chung River, any surface runoff, sewage and effluent discharge from Project site, during both construction and operational phases should be avoided. Measures to avoid, control and minimize the suspended solid, chemicals and other pollutants generated from marine works such as construction of piers, berthing facilities and columns of marine viaducts should be strictly effectively followed and regularly monitored.

12. Strict compliance and enforcement of such measures are of particular importance, especially when discharge of wastewater or other pollutants from construction sites into ecologically sensitive areas are very difficult to rectify, and that dumping or stockpiling of such pollutants (e.g. C&D materials) offsite are usually difficult to monitor (see sections above).

13. The number of work vessels should be kept as minimum as possible, and the vessels should avoid approaching Tung Chung Bay and entering the nearby proposed or designated Marine Parks to minimize disturbances.

14. The project proponent should avoid bird collision on glass wall by avoiding the use of large-sized glass surface in infrastructures such as depot, stations and other associated works, or taking proper preventive measures, such as applying patterns or stickers on the glass, installing bird deterrent devices or screens, or adjusting the reflectivity or transparency of the glass.

15. Glare impacts from lighting of the proposed project on surrounding areas and wildlife should be minimized if unavoidable.

Preventing Brownfield Proliferation

16. 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 captioned 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.

Climate Resilience

17. Since the Project’s structures are mostly in the coastal area, it should be fully considered the risks of extreme weather events, such as typhoons, heavy rains, sea level rise, etc. Latest conditions should be reviewed to ensure that the project can cope with possible extreme weather situations in the future.

18. The Project will provide an alternative transportation option served by autonomous transportation system with zero emission vehicles between Tung Chung, Airport Island and Hong Kong Port Island. However, the planned setting of the Project might also allow internal-engine vehicles to travel that emit air pollutants and carbon dioxide. Therefore, statutory restriction should be imposed on this road link to deter fossil-fuel vehicles.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email:

Yours faithfully,

LUI Tak Hang, Henry
Senior Conservation Manager
Green Power

Yours faithfully,

LUI Tak Hang, Henry
Senior Conservation Manager
Green Power