Policy Comments & Advocacy

Green Power would like to draw your attention to our concerns and recommendations regarding the Environmental Impact Assessment (EIA) Report for the Ngau Tam Mei Area (the Project). We would like to highlight several critical environmental issues that need to be addressed.

Land Uses

1. The Project site is located in close proximity to ecologically sensitive areas, including Lam Tsuen Country Park (LTCP), Wetland Conservation Area (WCA), Wetland Buffer Area (WBA), and the "Deep Bay Wetland outside Ramsar Site" Priority Site for Enhanced Conservation. The Project will directly encroach upon and/or impose disturbance to these sensitive habitats, leading to habitat loss, fragmentation, and disturbance to wildlife. Hence, any land uses in the Project area should not compromise the ecological values and functions of the wetlands, especially the Inner Deep Bay Ramsar Site and its associated WCA and WBA. Particularly, high-rise buildings are definitely incompatible with the surrounding rural landscape and may possibly block the flight paths of the avifauna.

2. We know that a Recommended Outline Development Plan (RODP) has been drafted for the Project site. According to the statutory Ngau Tam Mei Outline Zoning Plan (Plan No. S/YL-NTM/14), about one fourth of the Project area is zoned as the "Green Belt" ("GB") in which "the planning intention of this zone is primarily for defining the limits of urban and sub-urban development areas by natural features and to contain urban sprawl as well as to provide passive recreational outlets. There is a general presumption against development within this zone." The "GB" is proposed to be replaced by "UniTown" in RODP that any potential loss of these natural features and ecological functions should be evaluated and fully mitigated in future development.

3. As large area of habitats is expected to be lost to the Project, LTCP should be considered to be extended and cover the “Conservation Area” to the southern part of the Project (i.e. Northwest slope of Kai Kung Leng) to halt further loss of habitats.

Brownfield Proliferation

4. A proper relocation and/or compensation plan for the existing brownfield operations in the Project site should be formulated in the early stage to prevent proliferation of unfavorable and uncontrollable brownfields to the nearby rural areas that leads to further loss of habitats and degradation of rural area in the NWNT. The relocation sites or facilities should be in place before the demolishment of existing operations to provide a fluent translocation.

5. For a long run, translocation of brownfield operations in New Development Areas should be supported with clear policy that can trigger swiftly an action plan for affected areas. It is not effective to resolve the issue on a project-by-project basis.

Wastewater

6. The Ngau Tam Mei Drainage Channel (NTMDC) within the Project site is directly connected to the Mai Po Inner Deep Bay Ramsar Site. In order to comply with the "zero discharge policy" for Deep Bay and protect the ecology of Ramsar Site, any untreated surface runoff generated from the Project site during both construction and operation phase should be prevented from discharging into NTMDC or its tributaries, other natural or man-made channels, stormwater drainage and wetlands directly.

7. A detailed Emergency Response Plan must be developed and implemented to address potential scenarios such as sewage pipeline ruptures during construction, outlining immediate containment, notification procedures, and remediation measures to protect nearby water bodies.

8. It is recommended that the project includes provisions for on-site pre-treatment facilities, such as grease traps and silt separators, for all applicable commercial and industrial units to prevent blockages and the discharge of harmful pollutants into the public sewer.

9. A "sustainable urban drainage system" (similar to that planned in Tung Chung West New Town Extension) should be seriously considered to incorporate into the Project to promote the climate resilience of the Project and treat the surface runoff of developed areas in Project site.

Solid Waste

10. Most of the areas adjoining the Project site are countryside places and fishponds, any fly-tipping and dumping of solid wastes generated from this Project will be hard to combat. Even if such incidents are spotted, reinstatement can seldom be implemented because of various reasons such as land ownership, landuse zoning and etc. Therefore, generation, transportation and disposal of solid wastes should be under stricter control.

11. Although a GPS or equivalent system will be implemented to monitor dump trucks, it is recommended to include areas such as countryside places, fish ponds and agricultural lands as "no-go" areas to protect those sensitive habitats. An instantaneous alarm system should be utilised that dump trucks will trigger the alarm system when they encroach these no-go areas. Penalty terms for deviation of vehicles from designated areas / routes should be clearly listed in relevant contracts for adequate control.

12. The project should formulate and implement a rigorous and quantified waste management plan (WMP) in which waste generation, storage, reuse, treatment, transportation and disposal of waste generated during construction phase are closely monitored and coordinated under organized forecast. The priority of waste management should follow the hierarchy of avoidance, reduction, reuse, recycling and treatment/disposal. In particular, the WMP should include minimization strategy for the immense volume of inert C&D materials, moving beyond general recommendations to set specific targets for reducing cut-and-fill and using prefabrication to lessen the burden on public filling facilities.

13. The WMP should also set a framework and provide facilities to address the municipal solid waste generated in operational phase, with defined targets and guaranteed infrastructure for source separation and food waste recycling to actively reduce landfill reliance. The WMP should aim at establishing a self-sustainable community operated by management agents/authorities supported by policies, administration and sufficient waste facilities to achieve a zero-waste New Development Area.

14. To mitigate health risks from asbestos, a preliminary survey of structures for demolition should be conducted during the planning stage, enabling better integration of abatement measures into the initial schedule rather than leaving it as a contractor-led task later.

Ecology

15. The Project will result in the permanent loss of 2.55 hectares of wetland habitats, specifically marsh/reed and natural watercourses, which are assessed to be of low to moderate ecological value but support several species of conservation importance. It is critically important that the proposed off-site wetland compensation of 2.55 hectares is implemented successfully, with a detailed Habitat Creation and Management Plan (HCMP) ensuring the new site achieves equal or greater ecological function and connectivity with the Kam Tin River system before the impacted habitats are destroyed.

16. The chosen off-site wetland compensation area is situated near the Sha Po ardeid night roost and could be affected by the planned Northern Metropolis Highway, introducing potential cumulative light, noise, and shading impacts. Close coordination with the highway project is necessary during the detailed design of the HCMP to incorporate specific measures, such as planting shade-tolerant vegetation under viaducts, to ensure the compensation site's ecological integrity is not compromised by the adjacent infrastructure.

17. The NTMDC is a significant flight corridor and foraging ground for waterbirds, including multiple species of conservation importance; therefore, the proposed revitalisation and the construction of elevated roads (L1, L2, L3) and potential pedestrian connections across it pose a notable risk of disturbance and bird collision. To mitigate this, the project must strictly enforce the use of non-reflective, bird-safe materials on all structures, ensure phased construction to retain sections of the channel as refuge, and maintain the planned 20-30m non-building "Open Space" buffers on both sides of the NTMDC to preserve its ecological function.

18. The proposed road connection to the San Tin Technopole will fragment the wooded habitats on Ngau Tam Shan, directly impacting species like the Leopard Cat (Prionailurus bengalensis) and Red Muntjac (Muntiacus vaginalis) and increasing the risk of wildlife-vehicle collisions. The recommended wildlife corridor and animal barrier system must be incorporated into the final road design, informed by the AFCD’s guidelines, and include continuous monitoring to ensure its effectiveness in facilitating safe animal movement across the development.

19. The assessment identifies several flora and less-mobile fauna species of conservation importance, such as the Incense Tree (Aquilaria sinensis) and Chinese Bullfrog, within the project footprint that are vulnerable to direct loss or injury. A rigorous pre-construction survey followed by a carefully managed transplantation and translocation program, conducted by qualified ecologists, is essential for these species, and its success must be verified through a multi-year post-translocation monitoring program. The locations of precious plants should not be exposed to minimize the risk of illegal plant collection. The temporary access paths and working places should be away from the locations of precious plants as far as possible.

20. Large-scale destructive hillfire incidents frequently occur in Kai Kung Leng, part of LTCP. In order to protect the woodlands neigbouring the Project site, site regulations for hillfire prevention should be clearly stipulated in the specifications of the works contract, including forbidding open burning of domestic, C&D and yard wastes, no smoking, no food cooking, etc. within and outside Project sites and country park areas. Portable firefighting equipment should be installed in the Project sites, especially in vicinity of vegetated areas.

21. Revitalization of NTMDC should commence in Phase 1 Development and be independent of other site clearance and site formation works of the Project to carry on its ecological function during the whole construction period. Also, early implementation of revitalisation and operation of revitalized NTMDC allows longer time for the plantation in the channel to establish. At the same time, longer monitoring period for the revitalized channel with established plantation can sort out the problems at the early stage that improve the future maintenance with adjustment.

22. Gabion blocks should be avoided to construct the revitalized NTMDC if the channel banks are proposed to be transformed into planting areas. Gabion blocks, albeit considered as natural, are not the right substratum for any plantation. First, the gabion blocks contain no soil to support growth of terrestrial plants, not to mention riparian or aquatic plants. Even the gaps between the rocks are filled with soil, plants are hard to establish because either the groundwater cannot reach the soil through capillary action or the soil is eventually flushed away by river flow.

23. Plantation with "ecobags" anchored on the surface of gabion blocks is often adopted as remedy. However, the layers of rocks cut off the ecobags from underground water supply and even worse drain off quickly any rain water or sprinkled water that lead to dependence on heavy irrigation for maintenance of vegetation on ecobags. On the other hand, the amount of soil in the ecobags and its nutrient content is too limited for roots development that make the plants difficult to perpetuate in ecobags. As a result, gabion blocks lure extensive growth of invasive exotic species such as Mikania micrantha (Mile-a-minute 薇甘菊).

24. Therefore, enhancing biodiversity of channel banks, either aquatic or terrestrial, with gabion blocks is extremely challenging. Suitable plant species for such desiccated material is very limited, even if grown on ecobags. Promoting biodiversity with gabion blocks is not the right approach and impractical in usual cases.

25. Moreover, construction with gabion blocks occupies larger construction footprint and deter restoration of native vegetation which has inhabited on original natural river banks/beds. Design of "blue-green channels" with gabion blocks will result in adverse consequences to environment, ecology and hydrology.

26. A total of 101 butterfly species (41% of number of species recorded in Hong Kong) were recorded within the assessment area, 16 of which are species of conservation importance. In particular, 5 butterfly species of conservation importance were recorded within the Project site. Although most of butterfly species of conservation importance were recorded in habitats outside the Project site and semi-natural and natural habitats, village/orchard and developed area/wasteland within the Project site, we do not agree that no mitigation measures are required because significant area of foraging ground and nectary and larval foodplants will be lost and butterfly population will be unambiguously affected.

27. It seems that the rich biodiversity of butterfly in the Project site is supported by mosaic of natural, semi-natural, vegetated and watercourse habitats which provide foraging grounds and probably nectary and larval foodplants. In order to mitigate the impacts on butterfly community, their habitats outside the Project site should not disturbed by the Project. Vegetation or water bodies should be retained or re-provided with ecologically friendly maintenance to act as buffer. Within the Project site, shrublands, wetlands and plantation should be allocated to allow growth of larval foodplants for butterfly species of conservation importance, such as Mango (Mangifera indica), Lychee (Litchi chinensis), Longan (Dimocarpus longan), Ginger Lily (Hedychium coronarium), Reed, Citrus spp., etc.

28. Similarly, odonate habitats outside the Project site should be properly buffered with vegetation and water bodies in the Project site. In the Project site, properly vegetated water bodies such as ponds, water courses, etc. should be established to mitigate the impacts on odonate community. As large area of wetlands will be lost to development in Northern Metropolis, wetlands with ecological benefit should be established whenever possible.

29. Native species are preferred for the compensatory plantation in view of the proximity of country park and "Conservation Area" to the Project sites. Invasive species, such as Leucaena leucocephala, should be removed in the compensatory habitats and plantation sites during construction and operation phase to restore the ecological functions.

30. A prominent increase in population in the Project area is anticipated. Therefore, the road and footpath networks should be designed in a way that deters people from entering the ecologically sensitive areas.

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).