Dr. CHUIHo Kwong, Samuel, JP
Directorof Environmental Protection
EIAOrdinance Register Office
EnvironmentalProtection Department
(E-mail: eiaocomment@epd.gov.hk)
Green Power would like to draw your kind attention to our grave concerns about the above-captioned Project Profiles (PP) which has neglected several well-recognized potential environmental and ecological impacts of Water Recreation and Yacht Bay Development (the Peoject) on North Lantau water and coastal environment and ecology, including Tung Chung River cum Bay and Tai Ho Wan which is a designated Ecological Important Stream/River (EIS) and Site of Special Scientific Site (SSSI) respectively.
Key Concerns
1. Green Power is particularly concerned about some key issues related to the Project:
(a) the Project should not impose adverse impacts on the ecology, water quality, hydrology and environment of Tai Ho Bay and Tung Chung Bay to which the natural river mouths of Tai O Stream and Tung Chung River feed respectively and at both sites high biodiversity of flora and fauna are found.
(b) the Project should not impose adverse impacts on the ecology, water quality, hydrology and environment of Tung Chung EIS and its river basin in Tung Chung West.
(c) (c) the Project should not trigger any environmental and ecological vandalism on North Lantau shores, marine environment, especially the proposed and designated Marine Parks, and rural and natural habitats on Lantau.
Waste Disposal and Prevention of Eco-vandalism
2. There will be large amounts of C&D materials and sediments generated from the Project which will lead to eco-vandalism with flytipping and illegal dumping on land and at sea. We strongly urge the implementation of the tracking and monitoring of vehicle routes through GPS systems, and opine that control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles, especially dump trucks, from engaging in illegal dumping activities.
3. Flytipping of C&D waste occurs from time to time that threaten the ecologically significant and vulnerable Tung Chung River cum Bay and its river basin. The Project site is not far from Tung Chung West rural area and Tung Chung Bay. A GPS or equivalent system will be implemented to monitor dump trucks. It is recommended to include areas south of Tung Chung urban town as “no-go” areas to protect mangroves in “CPA” zones, riparian areas in “CA” zones and planned River Park area. An instantaneous alarm system should be utilised that dump trucks will trigger the alarm system when they encroach these no-go areas.
4. In order to protect the ecosystem and natural environment of Tung Chung River Valley cum Bay and South Lantau from air pollution and illegal dumping, large vehicles, construction / dump trucks and similar machineries associated with the Project must be prohibited from entering the section of Tung Chung Road between Ha Ling Pei and Shek Mun Kap, and all sections of South Lantau Road, as well as Chung Mun Road and section of Yu Tung Road to the west of Chung Yan Road. Vehicles that have justified reasons for entering need to seek formal approval from relevant authorities and be closely monitored (e.g. using GPS devices).
5. If barges/vessels are used for transporting any materials related to the Project, it is appreciated to equip the real-time GPS tracker on the vessels to combat the waste dumping at sea problem. Such a surveillance system should be capable of detecting and reporting any suspected irregularities in a timely manner.
6. The fly-tipping control measures, including but not limited to the above-mentioned “no-go” areas, GPS system and alarm system to control tracks of vehicles and vessels should be implemented with deterrent clauses incorporated in the works contracts. Stringent documentation, verification and monitoring should be implemented.
Aquatic biodiversity, fisheries and water quality
7. The preliminary assessments and corresponding mitigation measures mentioned in PP cannot be justified without provision of adequate baseline ecological data. The impacts on Tung Chung River cum Bay and Tai Ho SSSI is totally omitted in the PP where is not only rich in biodiversity and the spawning and nursery ground for commercial seafood, but also one of few remaining natural and intact river mouths of local large rivers.
8. After completion of the breakwaters, the water flow pattern in the vicinity of the Project will be permanently altered. Hydrodynamic and water quality impact assessment will be conducted to assess and avoid impacts on Tung Chung River cum Bay and marine parks.
9. Although the PP suggests to implement measures to avoid water pollution, total elimination of sewage discharged from construction sites is rarely seen in practice. Pollutant generating activities, especially the marine construction works, require implementation and close monitoring with due diligence to protect the water quality of the nearby marine area, especially for the ecologically important Tung Chung Bay where large area of mangrove, seagrass and mudflat located.
10. In order to conserve the ecology and water quality of Tung Chung River Valley cum Bay, the proposed works of the Project should have no association, direct or indirect, to any lands and activities in Tung Chung West, i.e. areas to the west of Chung Yan Road and its connected northern section of Tung Chung Road, where numbers of conservation works are being or will be soon implemented under the Tung Chung New Town Extension Project, e.g. River Park.
11. 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 sediment 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 land-based work sites.
12. In order to avoid damage to ecology and deterioration of water quality of Tung Chung River mouth cum Bay, any surface runoff, sewage and effluent discharge from Project site, during both construction and operational phases should be avoided. Measures to avoid, control and minimize the suspended solid, chemicals and other pollutants generated from the Project works such as construction of piers, berthing facilities and breakwaters should be strictly effectively followed and regularly monitored.
13. In operation phase, the marine vessels and coastal facilities and structures of the Project will contain antifouling agents/paints which will leach or flank off in the water. These chemicals are toxic in low concentration to many marine life and shellfish. In view of large fleet of vessels berthed in the Project site, the leached/flaked off antifouling agents/paints will affect the survival of marine and coastal wildlife that a comprehensive ecotoxicity assessment should be conducted. On the other hand, water quality impact of antifouling agents/paints to the users of the Water Park should also be assessed and avoided.
14. Strict compliance and enforcement of such measures are of particular importance, especially when discharge of wastewater or other pollutants from construction sites into ecologically sensitive areas are very difficult to rectify, and that dumping or stockpiling of such pollutants (e.g. C&D materials) offsite are usually difficult to monitor.
15. The number of work vessels should be kept as minimum as possible, and the vessels should avoid approaching Tung Chung Bay and entering the nearby proposed or designated Marine Parks to minimize disturbances.
16. Accidental Spillage Prevention and Response Plan shall be prepared to prevent and control accidental spillage. This plan should be available and approved in prior to issuance of Environmental Permit.
17. The Project proponent should avoid bird collision on glass wall by avoiding the use of large-sized glass surface in the facilities, structures and building, or taking proper preventive measures, such as applying patterns or stickers on the glass, installing bird deterrent devices or screens, or adjusting the reflectivity or transparency of the glass.
18. The active ingredients of watersport sunscreens contain a variety of chemicals including benzophenones which are toxic to marine life. In view of the large number of users of water wake park and inflatable water park, their consumption of sunscreens will contaminate the surrounding water of the Project site in operation phase. Proper assessments and preventive measures should be conducted and implemented to avoid water quality pollution with sunscreens’ chemicals by water wake park and inflatable water park users and yacht passengers.
Preventing Brownfield Proliferation
19. In order to avoid triggering uncontrollable development pressures on Lantau, especially Northeast Lantau, Tung Chung West, Tai Ho and natural coastlines, the works area of the captioned project should be clearly defined and fenced with restricted vehicular and pedestrian access. The project proponent, their contractors and subcontractors should not use any of the land areas on Lantau coast outside the works area especially Tung Chung West (i.e. areas west of Shun Tung Road, Tung Chung), Pak Mong, Ngau Kwu Long, Tai Ho, Tai Ho Wan, Yam O Wan, Yam O Tuk, Luk Keng Tsuen, Luk Keng Bay, Cheung Sok, Ha Kok Tsui, Yam Tsai Wan and undeveloped coastlines and areas on the outlying islands as works area, vehicle parking, vessel berthing, equipment storage, stock piling or other activities related to proposed works.
Climate Resilience
20. Since the Project’s structures are mostly in the coastal area, the risks of extreme weather events should be fully considered, such as typhoons, heavy rains, sea level rise, etc. Latest conditions should be reviewed to ensure that the project can cope with possible extreme weather situations in the future.
21. In conclusion, we consider that the PP has not provided sufficient data, conducted proper environmental and ecological assessments and recommended measures that address site-specific and project-specific environmental impacts. The water quality, waste pollution and ecological assessments are reckless that cannot identify obvious and important sensitive receivers, and common eco-vandalistic activities in the vicinity of the Project site. We are doubtful if the PP fulfills the Technical Memorandum of EIAO. Therefore, it is irresponsible if Environmental Permit is granted based on the current submitted PP.
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 grave concerns about the above-captioned Project Profiles (PP) which has neglected several well-recognized potential environmental and ecological impacts of Water Recreation and Yacht Bay Development (the Peoject) on North Lantau water and coastal environment and ecology, including Tung Chung River cum Bay and Tai Ho Wan which is a designated Ecological Important Stream/River (EIS) and Site of Special Scientific Site (SSSI) respectively.
Key Concerns
1. Green Power is particularly concerned about some key issues related to the Project:
(a) the Project should not impose adverse impacts on the ecology, water quality, hydrology and environment of Tai Ho Bay and Tung Chung Bay to which the natural river mouths of Tai O Stream and Tung Chung River feed respectively and at both sites high biodiversity of flora and fauna are found.
(b) the Project should not impose adverse impacts on the ecology, water quality, hydrology and environment of Tung Chung EIS and its river basin in Tung Chung West.
(c) (c) the Project should not trigger any environmental and ecological vandalism on North Lantau shores, marine environment, especially the proposed and designated Marine Parks, and rural and natural habitats on Lantau.
Waste Disposal and Prevention of Eco-vandalism
2. There will be large amounts of C&D materials and sediments generated from the Project which will lead to eco-vandalism with flytipping and illegal dumping on land and at sea. We strongly urge the implementation of the tracking and monitoring of vehicle routes through GPS systems, and opine that control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles, especially dump trucks, from engaging in illegal dumping activities.
3. Flytipping of C&D waste occurs from time to time that threaten the ecologically significant and vulnerable Tung Chung River cum Bay and its river basin. The Project site is not far from Tung Chung West rural area and Tung Chung Bay. A GPS or equivalent system will be implemented to monitor dump trucks. It is recommended to include areas south of Tung Chung urban town as “no-go” areas to protect mangroves in “CPA” zones, riparian areas in “CA” zones and planned River Park area. An instantaneous alarm system should be utilised that dump trucks will trigger the alarm system when they encroach these no-go areas.
4. In order to protect the ecosystem and natural environment of Tung Chung River Valley cum Bay and South Lantau from air pollution and illegal dumping, large vehicles, construction / dump trucks and similar machineries associated with the Project must be prohibited from entering the section of Tung Chung Road between Ha Ling Pei and Shek Mun Kap, and all sections of South Lantau Road, as well as Chung Mun Road and section of Yu Tung Road to the west of Chung Yan Road. Vehicles that have justified reasons for entering need to seek formal approval from relevant authorities and be closely monitored (e.g. using GPS devices).
5. If barges/vessels are used for transporting any materials related to the Project, it is appreciated to equip the real-time GPS tracker on the vessels to combat the waste dumping at sea problem. Such a surveillance system should be capable of detecting and reporting any suspected irregularities in a timely manner.
6. The fly-tipping control measures, including but not limited to the above-mentioned “no-go” areas, GPS system and alarm system to control tracks of vehicles and vessels should be implemented with deterrent clauses incorporated in the works contracts. Stringent documentation, verification and monitoring should be implemented.
Aquatic biodiversity, fisheries and water quality
7. The preliminary assessments and corresponding mitigation measures mentioned in PP cannot be justified without provision of adequate baseline ecological data. The impacts on Tung Chung River cum Bay and Tai Ho SSSI is totally omitted in the PP where is not only rich in biodiversity and the spawning and nursery ground for commercial seafood, but also one of few remaining natural and intact river mouths of local large rivers.
8. After completion of the breakwaters, the water flow pattern in the vicinity of the Project will be permanently altered. Hydrodynamic and water quality impact assessment will be conducted to assess and avoid impacts on Tung Chung River cum Bay and marine parks.
9. Although the PP suggests to implement measures to avoid water pollution, total elimination of sewage discharged from construction sites is rarely seen in practice. Pollutant generating activities, especially the marine construction works, require implementation and close monitoring with due diligence to protect the water quality of the nearby marine area, especially for the ecologically important Tung Chung Bay where large area of mangrove, seagrass and mudflat located.
10. In order to conserve the ecology and water quality of Tung Chung River Valley cum Bay, the proposed works of the Project should have no association, direct or indirect, to any lands and activities in Tung Chung West, i.e. areas to the west of Chung Yan Road and its connected northern section of Tung Chung Road, where numbers of conservation works are being or will be soon implemented under the Tung Chung New Town Extension Project, e.g. River Park.
11. 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 sediment 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 land-based work sites.
12. In order to avoid damage to ecology and deterioration of water quality of Tung Chung River mouth cum Bay, any surface runoff, sewage and effluent discharge from Project site, during both construction and operational phases should be avoided. Measures to avoid, control and minimize the suspended solid, chemicals and other pollutants generated from the Project works such as construction of piers, berthing facilities and breakwaters should be strictly effectively followed and regularly monitored.
13. In operation phase, the marine vessels and coastal facilities and structures of the Project will contain antifouling agents/paints which will leach or flank off in the water. These chemicals are toxic in low concentration to many marine life and shellfish. In view of large fleet of vessels berthed in the Project site, the leached/flaked off antifouling agents/paints will affect the survival of marine and coastal wildlife that a comprehensive ecotoxicity assessment should be conducted. On the other hand, water quality impact of antifouling agents/paints to the users of the Water Park should also be assessed and avoided.
14. Strict compliance and enforcement of such measures are of particular importance, especially when discharge of wastewater or other pollutants from construction sites into ecologically sensitive areas are very difficult to rectify, and that dumping or stockpiling of such pollutants (e.g. C&D materials) offsite are usually difficult to monitor.
15. The number of work vessels should be kept as minimum as possible, and the vessels should avoid approaching Tung Chung Bay and entering the nearby proposed or designated Marine Parks to minimize disturbances.
16. Accidental Spillage Prevention and Response Plan shall be prepared to prevent and control accidental spillage. This plan should be available and approved in prior to issuance of Environmental Permit.
17. The Project proponent should avoid bird collision on glass wall by avoiding the use of large-sized glass surface in the facilities, structures and building, or taking proper preventive measures, such as applying patterns or stickers on the glass, installing bird deterrent devices or screens, or adjusting the reflectivity or transparency of the glass.
18. The active ingredients of watersport sunscreens contain a variety of chemicals including benzophenones which are toxic to marine life. In view of the large number of users of water wake park and inflatable water park, their consumption of sunscreens will contaminate the surrounding water of the Project site in operation phase. Proper assessments and preventive measures should be conducted and implemented to avoid water quality pollution with sunscreens’ chemicals by water wake park and inflatable water park users and yacht passengers.
Preventing Brownfield Proliferation
19. In order to avoid triggering uncontrollable development pressures on Lantau, especially Northeast Lantau, Tung Chung West, Tai Ho and natural coastlines, the works area of the captioned project should be clearly defined and fenced with restricted vehicular and pedestrian access. The project proponent, their contractors and subcontractors should not use any of the land areas on Lantau coast outside the works area especially Tung Chung West (i.e. areas west of Shun Tung Road, Tung Chung), Pak Mong, Ngau Kwu Long, Tai Ho, Tai Ho Wan, Yam O Wan, Yam O Tuk, Luk Keng Tsuen, Luk Keng Bay, Cheung Sok, Ha Kok Tsui, Yam Tsai Wan and undeveloped coastlines and areas on the outlying islands as works area, vehicle parking, vessel berthing, equipment storage, stock piling or other activities related to proposed works.
Climate Resilience
20. Since the Project’s structures are mostly in the coastal area, the risks of extreme weather events should be fully considered, such as typhoons, heavy rains, sea level rise, etc. Latest conditions should be reviewed to ensure that the project can cope with possible extreme weather situations in the future.
21. In conclusion, we consider that the PP has not provided sufficient data, conducted proper environmental and ecological assessments and recommended measures that address site-specific and project-specific environmental impacts. The water quality, waste pollution and ecological assessments are reckless that cannot identify obvious and important sensitive receivers, and common eco-vandalistic activities in the vicinity of the Project site. We are doubtful if the PP fulfills the Technical Memorandum of EIAO. Therefore, it is irresponsible if Environmental Permit is granted based on the current submitted PP.
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