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 East Kowloon (the Project). We would like to highlight several critical environmental issues that need to be addressed.

Transit System

1. The EIA Report does not specify the type of transit system (e.g., monorail, light rail, trolleybus), making it impossible to assess environmental impacts accurately.

2. No disclosure or health impact assessment of "smart" technologies (e.g., electromagnetic fields). The environmental and health implications of unstated technologies remain unassessed.

3. The project's "green" claims (e.g., CO₂ reduction) should be quantified. No evidence or metrics provided to support environmental benefits.

Air Quality

4. The EIA Report projects that future background ozone (O₃) levels in 2027 and 2030 will exceed the Air Quality Objectives (AQOs), yet it fails to propose any specific mitigation measures to address this inevitable cumulative impact on Air Sensitive Receivers (ASRs) during the operational phase.

5. The cumulative impact assessment for the operational phase is insufficient, as it does not quantitatively assess the combined air quality impact from the Project's induced road traffic alongside other committed projects, particularly on ASRs already facing non-compliant pollutant levels.

6. We are concerned that the reliance on future PATH model projections showing a general improvement in air quality may lead to complacency; the EIA should commit to a pre-construction baseline monitoring program to verify these projections and provide a robust benchmark for EM&A.

7. The mitigation measures for gaseous emissions from construction vehicles, while noting the use of Euro VI standards "as much as practicable", should be made mandatory in the contract specifications to ensure these environmental benefits are realized.

8. The assessment for the operational phase is limited only to the Depot's VOC emissions, overlooking the need to quantify and substantiate the Project's "green" claims, such as the net reduction in vehicular emissions and carbon footprint by providing a mass transit alternative.

9. The EIA should include a specific commitment to using real-time air quality monitoring data at the most affected ASRs to dynamically manage construction activities, rather than relying solely on periodic TSP monitoring.

10. We recommend explicitly incorporating a commitment to using electric or zero-emission Non-Road Mobile Machinery (NRMM) where technologically and practically feasible, going beyond the existing regulatory requirements to further minimize on-site emissions.

Noise

11. The report comprehensively identifies potential noise impacts and proposes mitigation measures, but the effectiveness of quieter construction methods and QPME should be quantitatively validated during the CNMP stage to ensure compliance.

12. For transit system noise, while barriers are proposed, the transit technology (Trackless Tram vs. Guideway) option with inherently lower noise emissions should accord a higher priority in the selection to minimize reliance on secondary mitigation.

13. The assumption that groundborne noise from the transit system will be insignificant should be verified with pre-construction baseline vibration measurements at the closest NSRs to ensure no adverse impact is overlooked.

14. The Fixed Noise Source Management Plan (FNMP) is crucial; it should mandate a "quiet design" philosophy from the outset for all ventilation systems, PA systems, and depot equipment, integrating silencers and enclosures into the initial design.

15. The assessment of cumulative construction noise from concurrent projects is qualitative and over-optimistic; a more coordinated approach with other project proponents should be established to manage simultaneous works and prevent combined noise exceedances.

Water Quality

16. The permanent diversion of Ma Yau Tong Streams (WSR9) and other watercourses is a high-risk activity; it is recommended to implement real-time water quality monitoring downstream during and after diversion works to promptly detect and address any unforeseen pollution.

17. The assessment of cumulative impacts from concurrent projects is qualitative; a coordinated surface water management plan with other project proponents should be developed to manage combined runoff and prevent localized drainage system overload during construction.

Waste Management

18. For the substantial volume of C&D materials estimated at over 900,000 cubic meters, establishing clear, quantified goals for on-site reuse and off-site recycling rates would provide a stronger framework for monitoring and ensuring the project’s alignment with waste hierarchy principles.

19. 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.

20. The plan should explicitly incorporate the use of Building Information Modeling (BMI) or other digital tools during the design and construction phases to optimize material efficiency and minimize off-cuts, thereby reducing waste generation at the source.

Ecology

21. Enhanced pre-construction surveys for amphibians and freshwater invertebrates, particularly around NW-MYT8, are crucial and should be conducted immediately prior to works to confirm the presence of species like the Lesser Spiny Frog and Nanhaipotamon hongkongense, ensuring the capture and translocation plan is based on the most current data.

22. The mitigation strategy for artificial lighting during both construction and operational phases should be explicitly detailed, including the use of directional, fauna-friendly lighting with specific wavelengths and timing controls to minimise disruption to nocturnal species, particularly bats.

23. While the report concludes that bird collision risk with noise barriers is minor, a specific commitment should be made to incorporate proven anti-collision measures (such as fritting, patterns, or UV-reflective coatings) into the final design of all transparent or reflective barriers as a precautionary principle.

24. The cumulative impact assessment should be expanded to quantitatively assess the combined loss of woodland habitats from this project and other concurrent developments in East Kowloon, to ensure the overall ecological carrying capacity of the region is not compromised.

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).