Policy Comments & Advocacy

Green Power would like to draw your attention to our grave concerns and recommendations regarding the Environmental Impact Assessment (EIA) Report for the Tsing Yi – Lantau Link (the Project). We are disappointed that our recommendations put forward in public consultation of Project Profile have not been adopted in the EIA Report for critical environmental risks. We object to the EIA Report if our concerns and recommendations are not accepted in the EIA Report or included in Environmental Permit.

Forbid the Associated Construction Activities and Facilities on Lantau

1. We are gravely concerned about the potential massive uncontrollable and environmentally damaging dumping and flytipping on Lantau Island of construction & demolition (C&D) wastes generated from the Project. In fact, dumping of C&D waste have already been occurring in places such as Tung Chung West and Pui O on Lantau that has destroyed ecologically valueable wetlands, imposed flood risk to settlements, polluted natural rivers and seashores.

2. Regrettably, existing laws, including Town Planning Ordinance and Waste Disposal Ordinance, are either ineffective or invalid to combat these waste dumping cases committed on Lantau.

3. The EIA Report fails to provide effective and timely mechanisms to prevent illegal dumping and flytipping of C&D waste on Lantau Island, where enforcement is already challenging and reinstatement of damaged lands in ecological sense is almost unattainable.

4. As most areas on Lantau have not yet been covered by any statutory land use plans, no effective and efficient enforcement can be executed in most past incidents. As a result, the dumped wastes are hard to remove and the dumping sites are very unlikely to be reinstated. In many cases, the dumping sites have been taken up for further incompatible developments such as open storages, e.g. those in Shek Lau Po, Tung Chung.

5. The proposed Waste Management Plan is administrative and insufficient to prevent the irreversible environmental damage that illegal dumping causes to wetlands, rivers, seashores, and increases flood risk.

6. Ecologically important sites which are prone to be damaged by the wastes generated by the Project include Tai Ho Stream SSSI (also Ecologically Important Stream), Sunny Bay (habitats for Pipefish) and Tung Chung West (i.e. Tung Chung River basin) and Tung Chung Bay. Tai Ho River and Tung Chung River cum Bay nurtures the most and second richest freshwater species number respectively in the territory.

7. Therefore, in addition to the tracking and monitoring of vehicle routes of dump trucks/vehicles loaded with wastes (C&D, chemical and other wastes) through GPS or equivalent systems, control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles from engaging in illegal dumping activities and access to vulnerable areas for illegal dumping and flytipping. Penalty terms for deviation of vehicles from designated areas / routes should be clearly listed in relevant contracts for adequate control.

8. The dump trucks should be strictly prohibited from approaching and accessing to “No-go” areas, i.e. ecologically important sites mentioned in para. 6 and other identified sites, and Tung Chung Road and South Lantau Road.

Air Pollution

9. We note with concern the identification of a potential temporary concrete batching plant (CBP) on North Lantau, approximately 70m from the nearest Air Sensitive Receiver (ASR). This goes against our previous recommendation to forbid such facilities on Lantau. Its presence introduces a significant pollution source in countryside on Lantau.

10. To be consistent with the precautionary principle and to protect public health, we opine that the potential temporary CBP shall not be permitted on North Lantau. This measure is also essential to deter proliferation of brownfields on Lantau.

11. The air quality impact assessment (AQIA) relies on background air quality data from 2019-2023, which shows a historical trend of Air Quality Objectives (AQO) exceedances for RSP, FSP, and NO₂ at the Kwai Chung, Tuen Mun, and Tung Chung air quality monitoring stations. While a decreasing trend is noted, these areas remain some of the most polluted in Hong Kong. The assessment's conclusion of “no adverse impact” fails to adequately address the health risk to residents in these sensitive areas, who are already burdened by poor air quality.

12. According to EPD’s Air Quality Health Index(AQHI) data from 2014 to 2024, Tung Chung recorded 537 days with daily maximum AQHI ≥7 (about 13% in terms of number of days from 2014 to 2024) that is the third highest among all general air quality monitoring stations (The highest and second highest are Tuen Mun and Yuen Long respectively). More than 80% of these days with daily maximum AQHI ≥7 was dominated by ozone, i.e. ozone was the pollutant with the highest Added Health Risk for the maximum daily AQHI. Although ozone is not primary air pollutant generated from vehicles and its ambient level is greatly affected by regional situation and weather condition, nitrogen oxides emitted from vehicles are precursors of ozone which will contribute to the local ozone concentration.

13. Therefore, we are concerned that ozone has been omitted from the AQIA in the EIA Report. Also, the projection for air quality is too optimistic that may lead to an underestimation of the cumulative impacts of local and regional emission. The operational phase air quality model should be re-run using a more conservative background air quality scenario, ensuring it holds even if projected air quality improvements are delayed. The impacts of ozone should be considered in AQIA.

14. With blasting activities as close as 40m to an ASR (A03), more detailed assessment should have been conducted and corresponding mitigation measures should be provided.

Noise

15. The assessment defers critical noise mitigation details to a later Construction Noise Management Plan (CNMP) before the tender invitation and commencement of construction works, risking inadequate protection for nearby residents during construction.

16. Blasting noise is excluded from quantitative analysis. A specific management plan with monitoring and community notification is needed to address this significant disturbance.

17. Potential simultaneous construction with other major projects is not fully assessed. The CNMP must be updated to manage these combined noise effects.

Ecology

18. Direct impacts on protected species, especially the endangered Romer's Tree Frog (Liuixalus romeri) and coral colonies, require immediate pre-construction surveys and a professionally supervised translocation program before any construction activities to prevent population loss.

19. Risk of fire hills imposed by the Project should be eliminated. No smoking or fire ignition is allowed in Project site. Inflammable materials and chemicals/fuel should not be stored in the works areas near to streams and vegetation. Relevant personnel and workers should be notified in this regard before entering the work areas. Suitable fire-fighting equipment should be in place in the work sites.

20. The works boundary (e.g. tunnel portals) and access of the Project Site should be clearly delineated and physically fenced to prevent trespassing by project personnel to neighbouring habitats. Any identified and potential ecologically sensitive areas and species of concern should not be occupied, encroached or disturbed by works agents including but not limited to contractors, subcontractors, suppliers and associated service providers for related uses such as site offices, material/equipment/machinery installation and storage, stock piling, carparks, canteens, etc.

21. All personnel and workers of the Project should not poach or collect any wildlife or plants in the works areas. Also, no feeding of wildlife including but not limited to animals, birds and fishes by them is allowed. Dogs, cats or other domestic animals must be strictly prohibited to be kept in the Project Site.

22. Cumulative impacts from other concurrent infrastructure projects in North Lantau must be addressed through proactive regional coordination and a comprehensive environmental management plan to mitigate combined effects.

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).