政策倡議及咨詢

BY EMAIL ONLY
31
 
July
 
2024

Dr. CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)

cc.
Dear Dr. Chui,
就「啟德及東九龍智慧綠色集體運輸系統」工程項目簡介表達意見(只有英文版)
Project Profiles for Smart and Green Mass Transit System in East Kowloon (esb370) and Smart and Green Mass Transit System in Kai Tak (esb369)

Green Power would like to draw your kind attention to our concerns about the above-captioned Project Profiles (PP).

1. The proposed Smart and Green Mass Transit System (GTS) is proposed to be built in Kai Tak and East Kowloon which is a light and green transit system of medium to low carrying capacity. It will adopt environmentally friendly and smart technologies and operate on a dedicated corridor to improve the transport efficiency, safety and convenience, and will be separated from road traffic along the alignment which would not be affected by traffic conditions.

2. The proposed 7-km GTS in East Kowloon would connect the uphill areas of Kwun Tong to the nearby railway stations and major public transport interchanges which provide light and green transport feeder services in the northern uphill areas of Kwun Tong.

3. The proposed 3.5km long GTS connects the Kai Tak Cruise Terminal and residential areas at the former Kai Tak Runway Area and the MTR TML Kai Tak Station. A new depot is required and is proposed to be built at the Kai Tak Runway Area near the Kai Tak Cruise Terminal.

4. The PPs only stated GTS is an electrically powered transit system but have not indicated the type (monorails, light rails, trolleybus, trams, etc), scale of the structures, footprint of each GTS and their ancillary facilities. Green Power opines that the environmental impacts cannot be well identified and then no competent EIA can be conducted.

5. Different types of GTS may have different passenger carrying capacity and structural design  that lead to different project footprint, civil engineering design and works area/boundary during construction phase. These basic engineering factors affect the extent and amplitude of environmental impacts in both construction and operation phases.

6. In view of the vicinity of the proposed projects to residential areas and sensitive receivers such as schools and elderly homes, Study Briefs and/or Environmental Permit should be issued only if the types, scale, passenger capacity and alignment options of Mass Transit System have been proposed.

7. Also, the “smart” technologies involved in the proposed GTS have not been explained in the PPs that may have environmental or health implication such as electromagnetic field. In case that such “smart” and “green” facilities have not been included in the subsequently issued Study Briefs, their associated environmental impacts may be “officially” omitted in the whole EIA process that violates the purpose and spirit of EIAO.

8. The environmental performance of proposed GTS should also be quantified to verify its “green” claims, such as reduction in CO2-equivalent, air and water pollutants, noise level, amount of waste generated.

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 concerns about the above-captioned Project Profiles (PP).

1. The proposed Smart and Green Mass Transit System (GTS) is proposed to be built in Kai Tak and East Kowloon which is a light and green transit system of medium to low carrying capacity. It will adopt environmentally friendly and smart technologies and operate on a dedicated corridor to improve the transport efficiency, safety and convenience, and will be separated from road traffic along the alignment which would not be affected by traffic conditions.

2. The proposed 7-km GTS in East Kowloon would connect the uphill areas of Kwun Tong to the nearby railway stations and major public transport interchanges which provide light and green transport feeder services in the northern uphill areas of Kwun Tong.

3. The proposed 3.5km long GTS connects the Kai Tak Cruise Terminal and residential areas at the former Kai Tak Runway Area and the MTR TML Kai Tak Station. A new depot is required and is proposed to be built at the Kai Tak Runway Area near the Kai Tak Cruise Terminal.

4. The PPs only stated GTS is an electrically powered transit system but have not indicated the type (monorails, light rails, trolleybus, trams, etc), scale of the structures, footprint of each GTS and their ancillary facilities. Green Power opines that the environmental impacts cannot be well identified and then no competent EIA can be conducted.

5. Different types of GTS may have different passenger carrying capacity and structural design  that lead to different project footprint, civil engineering design and works area/boundary during construction phase. These basic engineering factors affect the extent and amplitude of environmental impacts in both construction and operation phases.

6. In view of the vicinity of the proposed projects to residential areas and sensitive receivers such as schools and elderly homes, Study Briefs and/or Environmental Permit should be issued only if the types, scale, passenger capacity and alignment options of Mass Transit System have been proposed.

7. Also, the “smart” technologies involved in the proposed GTS have not been explained in the PPs that may have environmental or health implication such as electromagnetic field. In case that such “smart” and “green” facilities have not been included in the subsequently issued Study Briefs, their associated environmental impacts may be “officially” omitted in the whole EIA process that violates the purpose and spirit of EIAO.

8. The environmental performance of proposed GTS should also be quantified to verify its “green” claims, such as reduction in CO2-equivalent, air and water pollutants, noise level, amount of waste generated.

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,

CHENG Luk Ki
Director, GREEN POWER

Yours faithfully,

CHENG Luk Ki
Director, GREEN POWER

二零二四年
七月
三十一日