October 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 Route 11 (Section between Yuen Long and North Lantau) (EIA-297/2023)

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

1. Water tunnels around or within Tai Lam Country Park are important roosting, wintering and/or breeding sites of bat species. As drill-and-blast for hard rocks will be adopted as the major construction method, we are highly concerned about its impacts on the bat populations inhabited in water tunnels, and on the structure of water tunnels. Independent and knowledgeable bat expert(s) should be engaged to monitor the bat communities in the water tunnels. Works should be suspended when the engaged bat expert(s) report(s) any abnormality of monitored bat communities.

2. There will be a huge amount of construction and demolition (C&D) materials generated during the construction phase of the project, e.g. 9,298,300 m3 inert C&D materials. Although the EIA report stated that the inert portion of the C&D materials would be reused on-site or offsite in concurrent projects as far as possible, e.g. only 7,701,700 m3 will be reused, more proactive and concrete plans to minimise and reuse various C&D materials as far as practicable is recommended.

3. The proposed project will generate a large amount of surplus C&D materials that will induce risk of illegal dumpling activities. In particular, the ecosystem and natural environment of Yam O Wan, Tai Ho Wan, Tung Chung River Valley cum Bay and South Lantau will be vulnerable to illegal dumping during construction phase from large vehicles, construction / dump trucks and similar machineries associated with the proposed project if entering the road at Tai Tsing Chau connected to Sunny Bay Road and Cheung Tung Road, and then Tung Chung Road and South Lantau Road.

4. 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.

5. It is recommended to include areas to the west of Tsing Chau Wan, areas to south of the alignment of Lantau Link (Ng Kwu Leng Section), and rural/countryside areas from Tuen Mun South, So Kwu Wat, Siu Lam, Tai Lam, Sham Tseng, Ching Lung Tau, Ting Kau, Yau Kom Tau as “no-go” areas to protect Lantau Island and vulnerable areas south of Tai Lam Country Park. Large vehicles, construction / dump trucks and similar machineries associated with the Project must be prohibited from entering these “no-go” areas. An instantaneous alarm system should be utilised that dump trucks will trigger the alarm system when they encroach these no-go areas. Vehicles that have justified reasons for entering need to seek formal approval from relevant authorities and be closely monitored (e.g. using GPS devices).

6. 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 contracts. Stringent documentation, verification and monitoring should be implemented.

7. 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.

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.

9. Sediments, soil, excavated materials should not be stockpiled near to the seashore, rivers or water channels to avoid wash down to water bodies during rainstorms.

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. The number of work vessels should be kept as minimum as possible, and the vessels should avoid approaching the natural coasts, proposed and designed Marine Parks and Fish Culture Zones to minimize disturbances to wildlife and maricultural activities.

12. Transplantation services will be provided by the project proponent if direct impacts on plant species of conservation importance are unavoidable. However, transplanted plants are often under great stress. It is recommended that in practice, the plants should be moved directly to their destination as soon as possible to avoid the need for temporary storage. Similar practice is also recommended for other species, especially the aquatic and water-dependent fauna species of conservation importance of the directed impacted watercourses.

13. The project proponent should avoid bird collision on glass wall by avoiding the use of large-sized transparent or highly reflective glass surface in infrastructures such as noise barriers/canopies, administration buildings, maintenance depot, workshops, stores 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.

14. Glare impacts from lighting of the proposed project on surrounding areas and wildlife should be minimized if unavoidable by adjusting the light intensity and illumination angles.

15. The Project should not trigger hillfires and slope soil erosion. Therefore, activities including but not limited to open burning and vegetation clearance outside the Project sites should be prohibited.

16. According to Environmental Protection Department’s yearly average Air Quality and Health Index (AQHI) data, Tung Chung and Tuen Mun ranked amongst the most polluting districts in terms of number of hours with AQHI ≥7 and days with daily maximum AQHI ≥7. Proposed Route 11 is part of the trunk road network that is connected to North Lantau Highway, Tuen Mun-Chek Lap Kok Road Link, proposed P1 Road, Tsing Yi-Lantau Link and possibly roads connected to reclamation in East Lantau water, the traffic flow to and from Lantau would be further increased and air pollution on Lantau, especially North Lantau and Tuen Mun, would be further deteriorated. Therefore, potential health impacts associated with the increased traffic induced by the Project should be assessed and comprehensive strategy should be formulated accordingly.

17. Since a significant part of the project is 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.

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