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 draw your kind attention to our views and comments about the above-captioned EIA Report.
1. The working site is located in a rural area with many ecologically valuable habitats nearby, especially the marshes, which are increasingly rare and valuable in Hong Kong. Particular care should be taken in the disposal of C&D waste as illegal dumping occurs from time to time. Although it is mentioned in Chapter 6 that a GPS or equivalent system will be used to monitor dump trucks, it is recommended to include habitats such as marshes, farmlands and South Lantau Road as “no-go” areas where dump trucks will trigger the alarm system, in the hope that this will prevent dumping from damaging those valuable habitats.
2. As species of conservation importance, particularly the Hong Kong Newt, have been observed within the boundaries of the works, thus rendering translocation necessary, we opine that programming of the works and measures to prevent translocated organisms from entering the work's sections during the construction phases should be carefully implemented.
3. Although no breeding activity of the Newt was observed during the surveys, the presence of up to 10 individuals in the stream channel may imply the presence of breeding populations around the section concerned. As the works will likely be conducted during the dry season, which overlaps with the breeding period of the Hong Kong Newt, the update ecological survey (as described in section 7.10.5) should accommodate the breeding period of the species. Barriers should also be established to prevent the Newt (which exhibits breeding site fidelity) and other species from entering the boundary of the works after translocation and before diversion is conducted. Continuous monitoring of areas around the works boundary and diversion channel should be done throughout the construction phase to ensure no wildlife is trapped. We also strongly recommend the engagement of experts and green groups during the detail design stage to ensure suitable habitats are available for these species in the modified channel.
4. Although the EIA report stated that any anticipated water pollution impacts could be avoided if the Best Management Practices (BMPs) are implemented, total elimination of sewage discharged from construction sites is rarely seen in practice. Pollutant generating activities, including excavation, construction of tidal gate, mechanical penstock and fish ladders, and river reprofiling works proposed in the EIA report, require implementation and close monitoring with due diligence to protect the water quality of rivers and bathing beach in Silver Mine Bay.
5. Any bare soil surfaces and temporarily stored loose materials should be covered and checked especially when rainstorms are anticipated, and kept away from rainfall or runoff. All sand/silt removal facilities should be adequately designed, checked and cleared to maintain sufficient removal capacity. Adequate barriers, such as silt curtains and perimeter channels should be provided to intercept all sewage or pollutants generated from the work sites.
6. The tidal gate at River Silver will block the watercourse and obstruct the wildlife movement. The closing period should be kept as minimum as possible.
7. The stormwater pumping station will be constructed on a patch of agricultural land. As the habitat quality of agricultural lands is not low, no further area of the agricultural land should be affected. Site boundary set in the agricultural land should be as minimum as possible. Material and equipment storage areas, carparks and other facilities associated with the construction should not be placed at the adjacent agricultural land or other natural habitats.
8. The cross bridge across Pak Ngan Heung River to the stormwater pumping station must be kept for maintenance access only during operation. No public access should be allowed to avoid unwanted activities such as dumping occur in the area.
9. Stormwater during adverse weather condition at upstream of Tai Tei Tong River will be diverted to Luk Tei Tong Bypass Channel via diversion box culvert. However, the level of water which will trigger diversion should be adjusted carefully in order to keep adequate water flow for downstream wildlife of Tai Tei Tong River.
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).
Green Power would like to draw your kind attention to our views and comments about the above-captioned EIA Report.
1. The working site is located in a rural area with many ecologically valuable habitats nearby, especially the marshes, which are increasingly rare and valuable in Hong Kong. Particular care should be taken in the disposal of C&D waste as illegal dumping occurs from time to time. Although it is mentioned in Chapter 6 that a GPS or equivalent system will be used to monitor dump trucks, it is recommended to include habitats such as marshes, farmlands and South Lantau Road as “no-go” areas where dump trucks will trigger the alarm system, in the hope that this will prevent dumping from damaging those valuable habitats.
2. As species of conservation importance, particularly the Hong Kong Newt, have been observed within the boundaries of the works, thus rendering translocation necessary, we opine that programming of the works and measures to prevent translocated organisms from entering the work's sections during the construction phases should be carefully implemented.
3. Although no breeding activity of the Newt was observed during the surveys, the presence of up to 10 individuals in the stream channel may imply the presence of breeding populations around the section concerned. As the works will likely be conducted during the dry season, which overlaps with the breeding period of the Hong Kong Newt, the update ecological survey (as described in section 7.10.5) should accommodate the breeding period of the species. Barriers should also be established to prevent the Newt (which exhibits breeding site fidelity) and other species from entering the boundary of the works after translocation and before diversion is conducted. Continuous monitoring of areas around the works boundary and diversion channel should be done throughout the construction phase to ensure no wildlife is trapped. We also strongly recommend the engagement of experts and green groups during the detail design stage to ensure suitable habitats are available for these species in the modified channel.
4. Although the EIA report stated that any anticipated water pollution impacts could be avoided if the Best Management Practices (BMPs) are implemented, total elimination of sewage discharged from construction sites is rarely seen in practice. Pollutant generating activities, including excavation, construction of tidal gate, mechanical penstock and fish ladders, and river reprofiling works proposed in the EIA report, require implementation and close monitoring with due diligence to protect the water quality of rivers and bathing beach in Silver Mine Bay.
5. Any bare soil surfaces and temporarily stored loose materials should be covered and checked especially when rainstorms are anticipated, and kept away from rainfall or runoff. All sand/silt removal facilities should be adequately designed, checked and cleared to maintain sufficient removal capacity. Adequate barriers, such as silt curtains and perimeter channels should be provided to intercept all sewage or pollutants generated from the work sites.
6. The tidal gate at River Silver will block the watercourse and obstruct the wildlife movement. The closing period should be kept as minimum as possible.
7. The stormwater pumping station will be constructed on a patch of agricultural land. As the habitat quality of agricultural lands is not low, no further area of the agricultural land should be affected. Site boundary set in the agricultural land should be as minimum as possible. Material and equipment storage areas, carparks and other facilities associated with the construction should not be placed at the adjacent agricultural land or other natural habitats.
8. The cross bridge across Pak Ngan Heung River to the stormwater pumping station must be kept for maintenance access only during operation. No public access should be allowed to avoid unwanted activities such as dumping occur in the area.
9. Stormwater during adverse weather condition at upstream of Tai Tei Tong River will be diverted to Luk Tei Tong Bypass Channel via diversion box culvert. However, the level of water which will trigger diversion should be adjusted carefully in order to keep adequate water flow for downstream wildlife of Tai Tei Tong River.
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).
Yours faithfully,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power
Yours faithfully,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power