Policy Comments & Advocacy

Green Power would like to draw your attention to our concerns and recommendations regarding the Project Profile (PP) for the Northern Metropolis Highway - Kwu Tung Section (the Project). We have reviewed the PP and would like to highlight several critical environmental issues that need to be addressed.

1. Ecological Impacts

The Project threatens ecologically sensitive areas, including:

• Wetland Conservation Area (WCA) and Wetland Buffer Area (WBA) near Ng Tung River and Ma Tso Lung.

• Long Valley Priority Site and Ho Sheung Heung fishponds, vital for migratory birds and aquatic species.

• Flight corridors along Ng Tung River and firefly hotspots (Fu Tei Au Road).

• Ma Tso Lung (seasonal) marsh, significant habitat for dragonflies Rhodothemis rufa and Urothemis signata. ⁽¹⁾

We urge the Proponent to:

• Avoid direct encroachment on recognized conservation sites. Prioritize habitat preservation over mitigation.

• Conduct year-round ecological surveys, including migratory bird assessments, to update baseline data.

• Implement wildlife corridors and compensation habitats for unavoidable losses.

2. Tunnel Construction Risks

The proposed Drill & Blast (D&B) method for Crest Hill tunnel lacks critical assessments:

• Blasting vibrations may destabilize slopes and affect nearby villages (e.g., Ma Tso Lung).

We recommend:

• Blasting controls: Limit charge weights, avoid high-wind periods, and install vibration monitors.

3. Water Quality & Hydrology

The Project intersects Ng Tung River and Ma Tso Lung Stream, which feed into the Inner Deep Bay Ramsar Site. Risks include:

• Construction runoff polluting fishponds, wetlands and river water.

Mitigation measures must:

• Enforce "zero discharge" for sewage and construction site stormwater.

• Prohibit in-stream works (e.g., non-dredging methods for viaduct piers).

4. Cumulative Impacts

The Project overlaps with San Tin Technopole, Kwu Tung North NDA, and Northern Link, yet cumulative impacts are superficially addressed.

We stress:

• Holistic air/noise assessments for concurrent projects.

• Low-carbon transport (e.g., electric vehicle incentives) to reduce emissions in pollution-prone Yuen Long.

5. Waste Management & Illegal Dumping

Rural areas near the site are vulnerable to fly-tipping.

We propose:

• GPS tracking for dump trucks to prevent illegal dumping in wetlands.

• Strict penalties in works contracts.

6. Cultural Heritage

Four archaeological potential areas (per EIA-213/2013) lie within the Project boundary.

We urge:

• Cultural Heritage Impact Assessment (CHIA) with AMO oversight.

7. Public Consultation

We urge the Project proponent to arrange public consultations once sufficient information is available. This will ensure that the concerns of the local community and environmental groups are addressed.

Thank you for your attention to these matters. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).