Dr.CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)
Green Power would like to comment on the above-captioned Project Profile (PP) under Environmental Impact Assessment (EIA) Ordinance:
Air Pollution
1. With ongoing/potential development of major infrastructures connected to or in vicinity to the above-captioned proposed project (the Project) (listed in section 2.3.1, PP), cumulative impacts of the Project on air quality of western territory (includes Yuen Long, Tuen Mun, Tung Chung, Kwai Chung, Tsuen Wan, Central/Western) must be assessed with reliable and updated data. According to the statistics of Environmental Protection Department, Tung Chung, Tuen Mun and Yuen Long station have recorded the highest annual number of hours with Air Quality Health Index (AQHI) equal to 7 or above levels since 2014. The health risk associated with the Project on the air sensitive receivers should not be increased under the current background of AQHI records.
2. Therefore, in order to safeguard the air quality and the health of residents affected by the proposed project, we opine that <u>the Project shall not use any of the land area on North Lantau as works area, vehicle parking, equipment storage or other related activities (especially concrete batching plant). The vehicles, vessels and machineries associated with the proposed Project should not be allowed to access to Lantau Island except the delineated works area directly required by the Project.</u>
Forbid the Associated Construction Activities and Facilities on Lantau
3. We are gravely concerned the potential massive uncontrollable and environmentally damaging dumping on Lantau Island of construction & demolition (C&D) wastes generated from the project. In fact, dumping of C&D waste have already been occurring in places such as Tung Chung West and Pui O on Lantau that has destroyed ecologically valueable wetlands, imposed flood risk to settlements, polluted natural rivers and seashores.
4. As most areas on Lantau have not yet been covered by any statutory land use plans, no effective and efficient enforcement can be executed in most past incidents. As a result, the dumped wastes are hard to remove and the dumping sites are very unlikely to be reinstated. In many cases, the dumping sites have been taken up for further incompatible developments such as open storages, e.g. those in Shek Lau Po, Tung Chung.
5. Therefore, to be consistent and to protect the environment, ecology, air and water quality, and natural landscape of Lantau from the adverse impacts of the Project, we stress and re-iterate our recommended measures stated in paragraph 2 and 6 of this letter.
6. We recommend the tracking and monitoring of vehicle routes of dump trucks/vehicles loaded with wastes through GPS or equivalent systems, and opine that control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles from engaging in illegal dumping activities. Penalty terms for deviation of vehicles from designated areas / routes should be clearly listed in relevant contracts for better control.
7. <u>We object to the above-captioned Project</u> if our recommended measures to prevent environmental deterioration of Lantau consequential to the this Project stated in paragraph 2 and 6 of this letter are not adopted as clause(s) in the Study Brief and Environmental Permit under Environment Impact Assessment Ordinance.
Noise
8. Also, with ongoing/potential development of major infrastructures connected to or in vincity to the Project (listed in section 2.3.1, PP), cumulative noise impacts from the Project (both construction and operation phase), aircrafts and vessels on noise sensitive receivers must be adequately assessed with reliable and updated data.
Ecology
9. Ecological survey and assessment should be conducted for the designated boundary of the Project to identify any ecologically sensitive habitats and/or species.
10. Impacts on Chinese White Dolphins, Brothers Marine Park and mariculture zones should be adequately assessed. Marine works and wastewater (including sewage and stormwater) discharge to the sea should be avoided.
11. In general, the PP has not included particular environmental and ecological data that can let the public perceive the scale of potential impacts. Consequently, no meaningful and concrete comments can be provided. We opine that more detailed environmental and ecological data should be provided in EIA reports with effective measures to avoid environmental and ecological impacts as priority.
Thank you very much for your kind attention.
Green Power would like to comment on the above-captioned Project Profile (PP) under Environmental Impact Assessment (EIA) Ordinance:
Air Pollution
1. With ongoing/potential development of major infrastructures connected to or in vicinity to the above-captioned proposed project (the Project) (listed in section 2.3.1, PP), cumulative impacts of the Project on air quality of western territory (includes Yuen Long, Tuen Mun, Tung Chung, Kwai Chung, Tsuen Wan, Central/Western) must be assessed with reliable and updated data. According to the statistics of Environmental Protection Department, Tung Chung, Tuen Mun and Yuen Long station have recorded the highest annual number of hours with Air Quality Health Index (AQHI) equal to 7 or above levels since 2014. The health risk associated with the Project on the air sensitive receivers should not be increased under the current background of AQHI records.
2. Therefore, in order to safeguard the air quality and the health of residents affected by the proposed project, we opine that <u>the Project shall not use any of the land area on North Lantau as works area, vehicle parking, equipment storage or other related activities (especially concrete batching plant). The vehicles, vessels and machineries associated with the proposed Project should not be allowed to access to Lantau Island except the delineated works area directly required by the Project.</u>
Forbid the Associated Construction Activities and Facilities on Lantau
3. We are gravely concerned the potential massive uncontrollable and environmentally damaging dumping on Lantau Island of construction & demolition (C&D) wastes generated from the project. In fact, dumping of C&D waste have already been occurring in places such as Tung Chung West and Pui O on Lantau that has destroyed ecologically valueable wetlands, imposed flood risk to settlements, polluted natural rivers and seashores.
4. As most areas on Lantau have not yet been covered by any statutory land use plans, no effective and efficient enforcement can be executed in most past incidents. As a result, the dumped wastes are hard to remove and the dumping sites are very unlikely to be reinstated. In many cases, the dumping sites have been taken up for further incompatible developments such as open storages, e.g. those in Shek Lau Po, Tung Chung.
5. Therefore, to be consistent and to protect the environment, ecology, air and water quality, and natural landscape of Lantau from the adverse impacts of the Project, we stress and re-iterate our recommended measures stated in paragraph 2 and 6 of this letter.
6. We recommend the tracking and monitoring of vehicle routes of dump trucks/vehicles loaded with wastes through GPS or equivalent systems, and opine that control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles from engaging in illegal dumping activities. Penalty terms for deviation of vehicles from designated areas / routes should be clearly listed in relevant contracts for better control.
7. <u>We object to the above-captioned Project</u> if our recommended measures to prevent environmental deterioration of Lantau consequential to the this Project stated in paragraph 2 and 6 of this letter are not adopted as clause(s) in the Study Brief and Environmental Permit under Environment Impact Assessment Ordinance.
Noise
8. Also, with ongoing/potential development of major infrastructures connected to or in vincity to the Project (listed in section 2.3.1, PP), cumulative noise impacts from the Project (both construction and operation phase), aircrafts and vessels on noise sensitive receivers must be adequately assessed with reliable and updated data.
Ecology
9. Ecological survey and assessment should be conducted for the designated boundary of the Project to identify any ecologically sensitive habitats and/or species.
10. Impacts on Chinese White Dolphins, Brothers Marine Park and mariculture zones should be adequately assessed. Marine works and wastewater (including sewage and stormwater) discharge to the sea should be avoided.
11. In general, the PP has not included particular environmental and ecological data that can let the public perceive the scale of potential impacts. Consequently, no meaningful and concrete comments can be provided. We opine that more detailed environmental and ecological data should be provided in EIA reports with effective measures to avoid environmental and ecological impacts as priority.
Thank you very much for your kind attention.
Yours faithfully,
Cheng Luk-ki
Director, Green Power
Yours faithfully,
Cheng Luk-ki
Director, Green Power