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 - Tin Shui Wai Section (the Project). We have reviewed the PP and would like to highlight several critical environmental issues that need to be addressed.

Ecological Impacts

1. The proposed alignment threatens internationally important habitats including the Mai Po Inner Deep Bay Ramsar Site, associated Wetland Conservation Areas, and ecologically sensitive zones such as Nam Sang Wai and Fung Lok Wai fishponds which provide stop-over and wintering sites for globally and regionally significant number of migratory birds. These wetland areas also serve as vital corridors for migratory and resident birds and support species of conservation importance such as Eurasian Otter (Lutra lutra). We strongly recommend avoiding any direct encroachment on these recognized conservation sites, prioritizing habitat preservation over mitigation.

2. Comprehensive year-round ecological surveys must be conducted to update baseline data, especially for species with few monitoring data such as Eurasian Otter. Wildlife corridors should be implemented with adequate design and alignment for any unavoidable habitat fragmentation.

3. The alignment of the highway must be kept to the south of the Kam Tin River old channel to avoid encroaching the Wetland Conservation Area (WCA) in Nam Sang Wai. This will help preserve the ecological value of this sensitive area.

4. The Project must not disconnect existing or proposed ecological linkages between habitats at Kai Shan and Chu Wong Ling, and should instead enhance these linkages wherever possible. This includes designing the Project to facilitate animal movement and plant dispersal, thereby supporting the overall ecological integrity of the area.

5. We call for a review of the compensation wetlands at the road interchange in Au Tau (surrounded by Yuen Long Highway and Tsing Long Highway), which were established for the Route 3 project. The ecological functions of these wetlands should be enhanced to ensure they effectively mitigate the impacts of the Project. This may include improving habitat diversity, water quality, and connectivity to adjacent natural areas.

Water Quality & Hydrology

6. The Project intersects Shan Pui River and Kam Tin River, which are integral to the Inner Deep Bay Ramsar Site. Construction runoff poses significant risks to these water bodies and adjacent wetlands. We insist on a strict “zero discharge” policy for stormwater and sewage in both construction and operation phase, and prohibit in-stream works while employing non-dredging methods for viaduct piers.

Design Specifics

7. To prevent further environmental degradation, we strongly advise against constructing slip roads that connect to Nam Sang Wai Road, Ho Chau Road, Pok Wai South Road, and Nam Sang Wai. Such connections could trigger the proliferation of brownfield sites, illegal dumping, and traffic congestion, ultimately ruining the ecology of the Ramsar Site by pollution and human disturbance. Instead, the Project should focus on minimizing additional access points that could lead to uncontrolled development and ecological damage.

8. The elevation of viaducts must not interfere with existing flight paths, particularly over Shan Pui River and Kam Tin River New Channel at Hung Mo Bridge, and should match structure elevations of existing bridges.

9. We recommend reducing the engineering footprint for tunnel portals. The design should minimize land take and disturbance to the surrounding natural environment. This can be achieved through careful planning and the use of environmentally sensitive construction techniques.

Cumulative Impacts

10. The cumulative impacts of the Project, in conjunction with other major developments such as San Tin Technopole, Northern Link, and Yuen Long Barrage Scheme, must be thoroughly assessed. Holistic ecological, air and noise impact assessments are essential to understand the combined effects on the environment, ecology and human health.

11. We advocate for the promotion of low-carbon transport options, such as electric vehicle incentives, to reduce emissions in the pollution-prone Yuen Long district.

Waste Management

12. Given the rural nature of areas adjoining the Project site, measures must be implemented to prevent fly-tipping and illegal dumping. We propose the use of GPS tracking for dump trucks and the imposition of strict penalties in works contracts to deter illegal activities.

Cultural Heritage

13. The Project is in close proximity to culturally significant sites, including thirteen graded historic buildings and the declared monument I Shing Temple. A Cultural Heritage Impact Assessment (CHIA) with oversight from the Antiquities and Monuments Office (AMO) is essential to avoid vibration impacts from tunnelling and/or blasting activities.

Public Consultation

14. We urge the Proponent to arrange transparent public consultations once detailed EIA data is available. This will ensure that the concerns of the local community and environmental groups are adequately 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).