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 - New Territories North New Town 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 may threaten ecologically sensitive areas including Pat Sin Leng Country Park and Conservation Areas gazetted under the Man Uk Pin Outline Zoning Plan. These areas serve as important habitats for species of conservation importance including mammals, avifauna, herpetofauna, butterflies, odonates, and fireflies. 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. Wildlife corridors should be implemented with adequate design and alignment for any unavoidable habitat fragmentation, particularly between adjacent habitats.

3. The Project must not disconnect existing ecological linkages between natural habitats, 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.

4. We emphasize the importance of protecting Ng Tung River and Tan Shan River Ecologically Important Stream, which are vital ecological corridors. All construction works near these watercourses must employ stringent mitigation measures to prevent sedimentation and pollution.

Water Quality & Hydrology

5. The Project intersects Ng Tung River, Ping Yuen River and Tan Shan River, which are ecologically important watercourses. Construction runoff poses significant risks to these water bodies. We insist on a strict “zero discharge” policy for stormwater and sewage in both construction and operation phases.

6. Special attention must be paid to prevent groundwater drawdown or infiltration from tunnel construction, which could affect the hydrology of nearby streams and ecosystems.

Design Specifics

7. We recommend reducing the engineering footprint for tunnel portals and ventilation buildings. The design should minimize land take and disturbance to the surrounding natural environment through careful planning and environmentally sensitive construction techniques.

8. The elevation and alignment of viaducts must be carefully designed to avoid interference with flight lines of avian species, particularly near known egretries and roosting sites at Man Kam To and Ping Che.

Cumulative Impacts

9. The cumulative impacts of the Project, in conjunction with other major developments such as the NTN New Town New Development Area, Northern Link Eastern Extension, and Fanling North New Development Area, must be thoroughly assessed. Holistic ecological, air and noise impact assessments are essential to understand the combined effects on the environment and human health.

10. We advocate for the promotion of low-carbon transport options to reduce emissions in the region.

Cultural Heritage

11. The Project affects the Hung Leng Site of Archaeological Interest and areas requiring further archaeological survey as identified in previous EIA studies. A comprehensive Cultural Heritage Impact Assessment with oversight from the Antiquities and Monuments Office is essential to avoid impacts from construction activities, particularly vibration effects from tunnelling and/or blasting.

12. The Rain Stone Bearing an Inscription "God of Rain" (GHS28) located within the assessment area requires special protection measures during construction.

Waste Management

13. 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.

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).