政策倡議及咨詢

1. Green Power, a local charitable green group, is gravely concerned about the environmental and ecological impacts of the transport infrastructures proposed in “Transport Infrastructure for Our Future-Strategic Studies on Railwaysand Major Roads beyond 2030” (RMR2030) launched by Transport and Logistics Bureau, Highways Department and Transport Department. We would like to draw the kind attention of the Administration to our comments and opinions.

2. Transport and traffic have great impacts to local environment, habitats and living quality of the residential and working population that may contradict to the study objectives of RMR2030, i.e. Drive Development, Strengthen Connection and Improve Efficiency, if not planned and designed in a sustainable approach.

3. Transport sector is the major local emission source of greenhouse gases, air pollutants and noise nuisance. It accounts for about 20% of local greenhouse gas emission in 2020 ⁽¹⁾ and is major emission source of nitrogen oxides and volatile organic compounds ⁽²⁾ that leads to deteriorating ozone pollution in the territory in recent years. Increased levels of greenhouse gases, air pollutants and noise impose risks of extreme weather events, contribute to related chronic and acute diseases and cause disturbance to working and living environment of the public.

4. In contrary to “Drive Development”, any impetuous development of transport infrastructures will render the society loss of capacity towards sustainable development in terms of property damages/loss to extreme weather events, medical expenses due to health impacts of climate change and pollution, and physical and mental impairment due to environmental impacts. Also, substantial developable areas will be wasted or sterilized by improper design of transport infrastructures alignment and facilities.

5. The alignment of some developed major railways and roads dissects and/or fragment originally continuous districts that causes disconnection of communities, especially in rural areas. Such fragmentation not only disintegrates the social unity and disconnects the social activities of these areas, but also generates inconvenience in short-distant travel in these areas. This contradicts the study objective of achieving “Strengthen Connection”.

6. We regret that RMR2030 neglects the adverse impacts of vehicle growth. During 2012 to 2022, the total road length in Hong Kong increased by 6.4%, from 2090km to 2223km ⁽³⁾. However, the licensed vehicles increased remarkedly by 24.1%, from 653010 ⁽⁴⁾ to 810383 ⁽⁵⁾ in this decade. The figures point out growth of vehicles having lost control rather than deficiency of roads.

7. Building more roads does not necessarily lead to “Improve Efficiency”. On the other hands, traffic conditions will worsen in popular driving destinations such as new towns and CBDs with more frequent and severer traffic congestion as more vehicles flush in. More vehicles not only increase the air pollution levels, especially road-side, but also land required for car parks which will intensify the problem of land supply. The hidden costs of building more roads, such as addition traffic loading to the existing roads in developed areas and indirect lands required, should be fully addressed and avoided.

8. Roads and railways developments has also disturbed and damaged local important habitats that leads to loss of local and regional biodiversity. We are disappointed that RMR2030 have not taken into account biodiversity and climate change in view that the HKSAR Government has pledged to protect local biodiversity and combat climate change.

9. Agricultural lands should be preserved and impacts of proposed transport infrastructures on local agricultural lands and farming activities should be adequately assessed and mitigated, if unavoidable. Brownfields with incompatible development should be the priority for land resumption for transport infrastructures.

10. Decking of any channels and channelization of natural rivers/streams for transport infrastructures should be avoided. Flooding risk brought about by the proposed transport infrastructures should be fully studied and alleviated.

<u>HongKong-Shenzhen Western Rail Link (Hung Shui Kiu-Qianhai)</u>

11. Hong Kong-Shenzhen Western Rail Link (HSWRL) is a cross-border railway which alignment encroaches the ecologically sensitive Deep Bay area which are internationally important wetland shared by Hong Kong and Shenzhen. Locations and boundaries for its depot and associated cross-border facilities have not yet been allocated that implies greater environmental and ecological impacts, socio-economic cost to both Hong Kong and Shenzhen than revealed by the consultation document as larger land footprint will be involved.

12. HSWRL is incompatible with the planned Tsim Bei Tsui/Lau Fau Shan/Pak Nai Coastal Protection Park and Waterfront Promenade in the Northern Metropolis Development Strategy ⁽⁶⁾ under the premise of conserving the coastal ecological environment if at-grade or viaduct option is adopted for construction. In such cases, the planned waterfront promenade running from Tsim Bei Tsui to Pak Nai within the Coastal Protection Park to provide walking trails and cycle tracks for the public to enjoy the natural environment will be seriously disrupted by HSWRL.

13. As HSWRL has not been taken into account in the planning of Hung Shui Kiu New Development Area (HSK NDA), the proposed railway may bring about material change to the development strategy and planned land use of HSK NDA, i.e. Approved Hung Shui Kiu and Ha Tsuen Outline Zoning Plan. The HSWRL may defer, interfere or overturn the development plan and the schedule of HSK NDA development and associated works.

14. HSWRL will be connected to planned HSK Station of West Rail Line. The capacity of HSK Station will be overloaded because it not only serves the planned population of HSK NDA but also the additional cross-border passengers. The over-saturated West Rail Line will hamper the development of the NWNT and affect living quality of residents and commuters.

<u>Central Rail Link</u>

15. We opine that at-grade or viaduct options are not compatible to the environment of Country Parks.  We also worry that habitats in Kam Tin and Tai Lam Country Park will be seriously impacted by the railway alignment, depot and back-up facilities.

16. Large amounts of excavated materials generated from the construction works may trigger massive flytippings in the Northwest New Territories.

<u>Northern Metropolis Highway</u>

17. As underground karstic cavities exist as shallow as about 20 metres ⁽⁷⁾ below ground surface and are extensively found in Yuen Long area ⁽⁸⁾, tunnel option for Northern Metropolis Highway (NMH) may not be feasible in Wang Chau, Nam Sang Wai and Tai Sang Wai areas where its alignment goes through, or the construction cost will be terribly high.

18. On the other hand, in order to preserve the rich and sensitive ecology in Deep Bay area and fulfill Hong Kong’s obligation under the international treaty of Ramsar Convention, no at-grade or viaduct option for the alignment should be adopted in these areas, especially Deep Bay Ramsar Site and Wetland Conservation Area.

19. Then, we are gravely concerned about the alignment of NMH, especially those sections passing through wetlands, fishponds, important habitats or encroaching protected areas such as Lam Tsuen Country Parks, Ramsar Site, Wetland Conservation Area, Wetland Buffer Area, Conservation Area, etc.

20. Yuen Long and Northern are amongst the Air Quality Monitoring Stations that recorded the longest hours with AQHI higher than 7 ⁽⁹⁾ which indicates a short-term health risk to the people in these districts. NMH will increase the pollutants emission and further threaten the health of the further 2.5 million population in the Northern Metropolis.

21. As bad precedents, West Rail Line and Route 3 Highway had seriously fragmented the rural community and habitats in Kam Tin, such notorious impacts will be foreseen to repeat in massive scale if similar callous design is followed for NMH.

<u>Shatin Bypass</u>

22. We are highly concerned about the impacts of the proposed Shatin Bypass to the Water Gathering Grounds in Tai Po River basin, eastern slopes of Needle Hill and Grassy Hill regarding damages to the water supply facilities, such as water tunnels, and quality of collected potable water.

23. We also disagree any encroachment of Shing Mun and Kam Shan Country Park, and Tai Po Kau Nature Reserve by the proposed Shatin Bypass. Intrusion to natural steams, woodlands and other natural habitats in Tai Po River basin and in area between Tai Po Road and ridges connecting Grassy Hill, Needle Hill and Smugglers’ Ridge should be avoided.

<u>Tseung Kwan O-Yau Tong Tunnel</u>

24. In spite of “Green Belt” zoning and not within boundary of designated country Park, the natural habitats and vegetation of Black Hill should be protected and avoided from encroachment of any associated facilities, e.g. ventilation shaft, as far as possible. EIA and other statutory procedures should be followed.

25. Noise nuisance to the neighbouring community and facilities during construction and operation phase should be addressed by early public engagement, competent works planning and proper mitigation measures.

Thank you very much for your kind attention.