Policy Comments & Advocacy

Green Power would like to draw your attention to our concerns and recommendations regarding the Project Profile (PP) for Proposed Comprehensive Residential Development with Wetland Restoration Area at Various Lots in DD104 and Adjoining Government Land, Wing Kei Tsuen, Nam Sang Wai, Yuen Long (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 development threatens internationally important habitats including fish ponds and woodlands in the Deep Bay area, which are integral parts of the wetland ecosystem. These areas provide vital habitats for waterfowl and other wildlife. 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. This is critical given the Project’s location within Deep Bay Buffer Zone 2 and its proximity to Conservation Areas (CA) and the Mai Po Inner Deep Bay Ramsar Site. Surveys must cover all seasons to account for migratory waterbirds and must specifically target species of conservation importance, such as the Eurasian Otter (Lutra lutra), for which there is currently insufficient data in this specific locality.

3. The proposed development must not disconnect existing ecological linkages between habitats in the Deep Bay area 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. Wildlife corridors should be implemented with adequate design and alignment for any unavoidable habitat fragmentation.

4. The proposed Wetland Restoration Area (WRA) must be subject to a detailed, standalone assessment. The ecological objectives, target species, and habitat functions of the WRA must clearly defined. It must demonstrate how this constructed habitat will provide a net ecological gain that genuinely compensates for the permanent loss of existing habitats (even degraded ones) on-site and the significant indirect impacts of the development. Its design must ensure hydrological connectivity and ecological functionality, moving beyond a purely cosmetic landscape feature.

5. The proposed WRA should be established and function before the works for residential development and other infrastructures commence to provide continuous spatial and temporal ecological mitigation. Adequate ecological and environmental monitoring should be formulated and conducted since the construction of WRA in addition to the routine EM&A.

Water Quality and Hydrological Impact

6. The Project intersects with existing nullahs and drainage channels, which are integral to the Deep Bay ecosystem. 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 any necessary water crossings.

Design and Mitigation Specifics

7. To prevent further environmental degradation, we strongly advise against constructing additional access points that could lead to uncontrolled development and ecological damage. Instead, the Project should focus on minimizing additional access points that could lead to uncontrolled development and ecological damage.

8. The elevation of buildings must not interfere with existing flight paths of birds, particularly over the fish ponds and woodlands. 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.

9. Detailed measures to mitigate light and noise pollution from the residential development must be included, which will cause significant disturbance to nocturnal wildlife and birds in the adjacent wetland areas. This should include commitments to using wildlife-friendly lighting and acoustic barriers.

Cumulative Impacts

10. The cumulative impacts of the Project, in conjunction with other major developments in the area, 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.

Public Consultation

13. 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).