November 2023

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

Dear Dr. Chui,
Green Power’s Responses to the EIA Report of Tuen Mun Bypass

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

Cumulative Air Pollution Impact

1. According to Environmental Protection Department’s yearly Air Quality Health Index (AQHI) data, Tuen Mun ranked the most polluting district in terms of average annual numbers of HHR hours (hourly AQHI ≥7) and HHR days (daily maximum AQHI ≥7) in the past eight years(1).

2. Proposed Tuen Mun Bypass (TMB) (the Project) is part of the trunk road network consisting of North Lantau Expressway, Tuen Mun-Chek Lap Kok Tunnel Road, Lantau 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 and Northwest New Territories (NWNT) would be further increased and air pollution in Tuen Mun would be further deteriorated. Therefore, comprehensive cumulative air pollution impact assessment should be conducted.

Underground Water Drawdown

3. The project consists of construction of tunnels penetrating beneath the Tai Lam Country Park. In view that the granite bedrock is usually distributed densely with joints and may contain faults, the potentially occurred infiltration or drawdown of groundwater due to the tunnel construction will alter the hydraulics of the natural streams and reservoirs on the ground level. It may hence result in aquatic ecosystem degradation or loss, and reduced water discharge to the nearby reservoirs, i.e. Tai Lam Country Park and water gathering grounds of Tai Lam Reservoir, Hung Shui Hang Reservoir and Lam Tei Reservoir.

4. Unfortunately, such environmental impacts can be catastrophic but hard to accurately predict and mitigate. Therefore, a contingency plan should be formulated to cope with any abnormality in the nearby streams and reservoirs caused by the Project. Moreover, diversion of watercourses should be avoided as far as practicable.

Fly-tipping prevention

5. Construction and demolition (C&D) materials, chemical wastes, 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. Deterrent clauses should be incorporated in the work contracts to monitor and penalize any fly-tipping activities.

6. The proposed project will generate a large amount of C&D materials that will induce risk of illegal dumpling activities. The ecosystem and natural environment on Lantau are of particular concern if large vehicles, construction / dump trucks and similar machineries associated with the proposed project can access to Lantau Island through Tuen Mun-Chek Lap Kok Tunnel Road or Lantau Link via Tuen Mun Road.

7. Therefore, 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.

8. It is recommended to include Tuen Mun-Chek Lap Kok Tunnel Road, Tuen Mun Road (the section south of Kam Fai Garden), Castle Peak Road (the section south of Sam Shing Estate), Ng Lau Road, Hong Po Road, Tsing Lun Road, Castle Peak Road (the section north of Fuk Hang Tsuen Road) and vehicular accesses linking Fuk Hang Tsuen Road as “no-go” areas to protect Lantau Island and vulnerable areas in NWNT and 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.

9. 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).

10. 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.

Preventing Proliferation of Brownfield on Lantau

11. In order to avoid triggering uncontrollable development pressures on Lantau, especially Northeast Lantau, Tung Chung West, Tai Ho and natural coastlines, the project proponent, their contractors and subcontractors should not use any of the land areas on Lantau coast including 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 including Ma Wan, Tan Lung Chau as works area, vehicle parking, vessel berthing, equipment storage, stock piling or other activities related to proposed works.

Protecting Water Quality

12. 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.

13. Any bare soil surfaces and temporarily stored loose materials should be covered and checked especially when rainstorms are forecast, 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.

Working Vessels

14. The number of work vessels should be kept as minimum as possible, and the vessels should avoid approaching and berth at the natural coasts, proposed and designed Marine Parks and Fish Culture Zones to minimize disturbances to wildlife, e.g. the endangered Chinese White Dolphin, and maricultural activities.


15. 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.

16. 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.

17. 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.

18. Aboveground project footprint, including stockpiling site and worker stations etc., should not go beyond the designated boundary of the aboveground works area (i.e. zero footprints in ecologically sensitive areas and aboveground of Tai Lam Country Park).

19. 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.

20. It is recommended to select native tree species for the compensatory tree planting. Post-planting and post-transplanting monitoring and care should be taken place accordingly.

21. Similar practice is also recommended for other species, especially the aquatic and water-dependent fauna species of conservation importance of the directed impacted watercourses. The condition of hydrology, water quality and ecology of the recipient sites must be thoroughly assessed to ensure high survival rate.

Climate Resilience

22. Since part of the project is close to 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,

CHENG Luk-ki
Director, Green Power

Yours faithfully,

CHENG Luk-ki
Director, Green Power


(1)  A Brief Review of AQHI Data of Hong Kong for 2022, Green Power website: