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 Smart and Green Mass Transit System in Kai Tak (the Project). We would like to highlight several critical environmental issues that need to be addressed.

Transit System

1. The EIA Report does not definitively state the specific type of transit system (e.g., SkyShuttle vs. ART) and its detailed design parameters, making a precise assessment of its environmental footprint and impacts difficult.

2. The "green" claims are described qualitatively (e.g., battery-powered, reduced traffic) but are not robustly quantified with projected figures for CO2-equivalent reduction or other pollutant reductions compared to a "without project" scenario.

3. The potential environmental or health implications of "smart" technologies, such as electromagnetic fields, are not explicitly assessed or mentioned in the provided sections of the EIA Report.

4. The report should explicitly address the project's lifecycle environmental costs, including the disposal of batteries from the electric vehicles and the recycling of construction waste, to fully validate its “green” credentials.

Noise

5. The assessment of transit noise for the Autonomous Rail Rapid Transit (ART) system shows predicted levels very close to the legal criteria at several Noise Sensitive Receivers, suggesting that mitigation measures such as low-noise road surfacing and vehicle skirts should be mandated from the outset rather than being considered only "if necessary".

6. The reliance on future plans (CNMP, TNMP, FNMP) to finalize critical noise mitigation measures introduces uncertainty; the EIA should commit to specific, worst-case scenario mitigation strategies now to ensure compliance upon operation.

7. The cumulative construction dust and noise impacts with concurrent projects like Domestic Site 4B5 are acknowledged but assessed as not adverse; a more robust, quantitative cumulative impact assessment during the peak construction period would be prudent.

Water Quality

8. Given the proximity to the Kai Tak River, a key water sensitive receiver, it is recommended to enhance the Environmental Monitoring and Audit (EM&A) programme to include periodic water quality checks in the river during the most intensive construction phases adjacent to it, ensuring early detection of any inadvertent impacts despite the proposed mitigation measures.

Wastes

9. 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/parking locations should be clearly listed in relevant contracts for adequate control.

Visual Impact

10. While visual impacts are acknowledged and general mitigation is promised (aesthetically pleasing design), the report would benefit from a stronger commitment to specific architectural treatments and greening integration for the elevated viaduct to blend with the urban fabric.

11. The effectiveness of mitigation measures OM1 (Aesthetically Pleasing Design) and OM2 (Landscape Treatment) is paramount. The detailed architectural and landscape design in the next stage should be subject to a rigorous design review panel to ensure these measures are not just theoretical but are translated into a high-quality, visually integrated design that minimizes bulk and uses materials, colours, and forms sympathetic to the Kai Tak context.

Cultural Heritage

12. The precautionary measure to inform the Antiquities and Monuments Office (AMO) immediately upon any chance discovery of antiquities should be explicitly included in the contract specifications and the EM&A manual to ensure all contractors are aware of this legal requirement.

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).