Policy Comments & Advocacy

about the above-captioned Project Profile (PP). The proposed project (the Project), which involves an urban development covering approximately 179 hectares in Lung Kwu Tan (LKT) alongside extensive marine and land-based road infrastructural works, poses substantial risks to the highly sensitive coastal, marine, and terrestrial ecosystems of the Western New Territories.

While we acknowledge that the Project aims at supporting modern industries, the PP omits critical ecological baselines and relies heavily on deferred or simplified assessments. We urge the Environmental Protection Department (EPD) to ensure that the following key environmental issues are strictly addressed in the upcoming Environmental Impact Assessment (EIA) process.

Key Concerns

1. Green Power is particularly concerned about several key issues related to the Project:

(a) Severe Ecological and Habitat Disturbances: The Project is located in immediate proximity to critical ecological sensitive receivers, including LKT Village butterfly hotspot (one of few butterfly hotspot in Western New Territories), the Lung Kwu Sheung Tan (LKST) Egretry, the LKT Valley SSSI, Siu Lang Shui SSSI and the Sha Chau and Lung Kwu Chau Marine Park.

(b) Impacts on Species of Conservation Importance: The construction and operation of the 1,800-meter-long LKT Sea-crossing Bridge, offshore jetties, and submarine pipelines risk causing permanent habitat loss and severe disturbance to the Chinese White Dolphin (CWD) and endangered Horseshoe Crabs.

(c) Air Quality and Cumulative Regional Pressures: The Northwest New Territories (NWNT) is already highly vulnerable to regional air pollution. The introduction of heavy industries and increased heavy vehicle traffic risks exacerbating local health and environmental burdens.

Ecology and Biodiversity Safeguards

2. LKT is one of the few butterfly hotspots in the Western New Territories. 166 butterfly species (68% of total number of local butterfly species) have been recorded from Green Power's regular annual surveys from 2018 to 2025, including many concerned species such as Catochrysops panormus (Silver Forget-me-not, 藍咖灰蝶), Zizula hylax (Tiny Grass Blue, 長腹灰蝶), Megisba malaya (Malayan, 美姬灰蝶), Phalanta phalantha (Common Leopard, 琺蛺蝶), Cethosia biblis (Red Lacewing 紅鋸蛺蝶). The Project will bring about further disturbance of butterfly habitats in LKT area.

3. The waters around the Black Point next to the Project site have been identified as the "hot spot" of Sousa chinensis (Chinese White Dolphin 中華白海豚)(Grade 1 National Key Protected Species) where "dolphins regularly occurred in the past"⁽¹⁾, therefore we are worried that the Project will further worsen the survival of Chinese White Dolphin by the increase of marine traffic induced by the Project which population is seriously threatened in recent years.

4. The permanent marine habitat loss and underwater acoustic disturbances from the construction of the LKT Sea-crossing Bridge, piers, and offshore jetties pose a critical threat to the CWD. Given the critically low and declining population of CWDs in Hong Kong waters, any marine habitat degradation must be treated with the highest level of precaution. The alignment of the bridge must take into account the potential use by marine mammals, and a robust, long-term CWD monitoring and adaptive management plan must be mandated.

5. The shores of LKT and LKST are historically recognized nursery grounds for endangered Horseshoe Crabs (listed as "Endangered" on IUCN Red List). The EIA must include dedicated intertidal surveys for this species. To mitigate unavoidable coastal impacts, the Project proponent should study the feasibility to incorporate suitable soft-sediment substrata within the proposed eco-shorelines and green channels to actively restore intertidal nursery grounds.

6. The LKST Egretry is located close to the proposed works. The Project must implement enhanced mitigation, including a strictly enforced construction buffer zone, a total prohibition of noisy construction activities during the active bird breeding season, and continuous 24-hour disturbance monitoring.

Loss of Backshore Vegetation

7. Natural vegetated backshore is an ignored habitat which nurture a particular group of backshore plant species such as Caesalpinia bonduc (Gray Nickers 刺果蘇木), Vitex rotundifolia (單葉蔓荊). Locally backshore habitat is narrow band between seashore (around high tide mark) and terrestrial habitats. Therefore, these uncommon, detached, small-sized habitats were usually lost unawarely to developments such as roads, car parks, etc.

8. Backshore vegetation composing of native species is essential to sustain the coastal ecology by stabilizing the coastal soft substrata, maintaining native biodiversity. Therefore, backshore vegetation in LKT shores should be preserved in the development plan to protect the natural seashore landscape against wave erosion and for aesthetic purpose.

9. Upgrading roads at the back of seashores will take up coastal habitats and destroy backshore vegetation which not only sets a green backdrop for natural shores but also filter the polluted surface runoff and stabilize the natural shore, especially sandy beach, against wave erosion.

Prevention of Water Pollution and Hydrodynamic Impacts

10. The operation of offshore jetties and seawater intakes introduces risks of water pollution. Furthermore, the permanent pier foundations of the Sea-crossing Bridge will alter local hydrodynamic and flushing regimes, risking water quality deterioration and eutrophication in the adjacent engulfed bay and Green Channels.

11. We strongly urge that a comprehensive Green Channel Management and Water Quality Plan be required. The Environmental Permit must explicitly prohibit any effluent outfalls, construction site surface runoff, or untreated wastewater from discharging directly into local watercourses, Green Channels, or the surrounding marine environment. Silt curtains must be deployed for all marine works with stringent, real-time performance criteria and explicit contingency plans integrated into the EM&A framework.

12. Hydrological and hydraulic assessment should be conducted for the Green Channel feeding LKT Beach. The alignment of the channel should be designed to avoid erosion or sediment cumulation at LKT Beach.

Waste Management and Prevention of Eco-Vandalism

13. The massive volume of construction and demolition (C&D) materials, excavated marine sediments, and chemical wastes generated by large-scale land formation and road widening projects presents a severe threat of illegal dumping. The rural habitats, vegetated hillsides, and coastal areas surrounding LKT are highly vulnerable to eco-vandalism, fly-tipping, and landfilling of waste.

To combat this, a stricter waste transportation tracking and enforcement system is vital:

(a) Mandatory Real-Time GPS Tracking & Geofencing: All dump trucks and marine vessels engaged in the Project must be equipped with automatic GPS tracking systems to monitor their travel routes, vessel berthing, and parking locations in real time.

(b) "No-go Areas": In addition, "no-go areas" including areas such as countryside places, marine parks, villages, fish ponds and agricultural lands to protect those sensitive habitats must be designated. An instantaneous alarm system should be utilised that dump trucks/vessels will trigger the alarm system and alert responsible personnels when they encroach these "no-go areas".

(c) Enforceable Contractual Penalties: Deterrent clauses and strict "no-go" designations for ecologically sensitive areas must be explicitly incorporated into the specifications of works contracts.

Air Quality and Cumulative Regional Impacts

14. The PP acknowledges proximity to major regional emission point sources such as the Black Point Power Station, Castle Peak Power Station, and I-PARK2. The NWNT suffers from frequent ozone (O₃) and particulate exceedances. Relying solely on "separation distance" to substitute for detailed quantitative dispersion modeling of fugitive dust during earthworks is unacceptable.

15. The EIA must conduct quantitative air dispersion modeling for peak construction phases and include a comprehensive qualitative regional cumulative air impact assessment. Furthermore, to reduce industrial and vehicular emissions, the project proponent must commit to deploying Best Available Technology (BAT) and electrified Non-road Mobile Machinery (NRMM) across all work fronts.

Land Contamination

16. The project area contains extensive brownfield sites currently occupied by workshops, open storages, concrete works, and container yards. The land contamination assessment cannot be treated as a preliminary exercise. A detailed Site Appraisal, followed by a formal Contamination Assessment Plan (CAP) and necessary Site Investigations (SI), must be completely approved, and remediation executed, before any construction activities commence on affected land parcels.

Road Development

17. Current traffic of LKT Road is busy as it is the only vehicle access for the facilities in Tsang Tsui, e.g. WENT, T.Park, Y.Park, etc, Traffic congestion of LKT Road will be caused and worsened by additional heavy vehicles associated with the Project that seriously affects the villages to east of LKT Road.

18. Under the preliminary proposal, the Sea-crossing Bridge will serve the road-transportation need of LKT reclamation. The existing traffic load of LKT Road, mainly comprising heavy vehicles travelling to and from facilities in Tsang Tsui is not anticipated to be relieved because LKT Road will be still the shortest route if those facilities will still be operating.

19. Cumulative air quality assessment(s) for the worst-case scenario(s) that LKT Road continues to be the main route for heavy vehicles travelling to and from facilities in Tsang Tsui in operation phase should be conducted.

Proliferation of Brown Fields

20. Large area of lands in the adjoining proposed LKT Reclamation is currently occupied by brownfield operations. The proposed development will likely trigger the spillage of brownfields to the nearby rural areas and countryside, therefore a proper reallocation and/or compensation plan for the existing brownfield operations should be formulated in the early stage before the construction phase to prevent an expansion of unfavorable and uncontrollable land uses at the periphery of the proposed reclamation and/or LKT Village.

21. For interfacing with the existing land, land-based works of the Project including site clearance and site formation works, etc. will also be required along the coastal areas adjacent to the proposed reclamation. Activities associated with the Project, e.g. materials piling and machinery storage, should be prohibited from encroaching and/or disturbing existing habitats outside the Project boundary.

Evading Public Inspection

22. We regret that "The design details, including the locations of off-shore jetty(ies) and submarine pipeline(s) as well as construction methodology, are not available at the time of preparing this PP and would be developed at later stage." Without this basic information, it is unfair for the public to participate in consultation process under EIAO as solid and relevant comments cannot be lodged.

23. More importantly, an adequate Study Brief under EIAO cannot be formulated and consequently competent EIA cannot be conducted properly that jeopardizes the statutory EIA process. Therefore, details of different options for the locations of off-shore jetties and submarine pipelines as well as construction methodology must be provided in EIA report. Further EIA study for proposed off-shore jetties and submarine pipelines should be conducted to address any related public comments on the EIA Report of the Project. Any measures to mitigate the environmental/ecological impacts that are not proposed in EIA Reports should be included in Environmental Permit.

Conclusion

24. In conclusion, Green Power considers that the Project Profile downplays significant long-term impacts on marine mammals, endangered intertidal species, and regional air sheds. The forthcoming EIA Study Brief must mandate rigorous baseline data collection, explicit quantitative modeling, and legally enforceable conditions within the Environmental Permit to prevent irreversible ecological vandalism and environmental degradation in Lung Kwu Tan area.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).