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 attention to our concerns and recommendations regarding the Environmental Impact Assessment (EIA) Report for the Development of the Loop – Eastern Connection Road (the Project). We have commented the Project Profile of the Project dated 22 May, 2025, and we would like to highlight and re-iterate several critical environmental issues that need to be addressed.
Public Consultation and Responsiveness
1. The project proponent's response to public concerns, as summarized in Table 2.4 of the EIA Report, consolidates comments into five broad categories and fails to directly address several key issues raised by Green Power in our submission on the Project Profile. Specific concerns regarding land use compatibility with "Conservation Area" and "Wetland Conservation Area" zonings, prevention of fly-tipping, control of the works footprint, and impacts on hillfires and the planned Wetland Conservation Parks System are not notably addressed from the proponent’s summary and lack a corresponding direct response.
Air Quality
2. The Air Quality Impact Assessment (AQIA) relies heavily on the assumption that all road-based public transport serving the Loop will be zero-emission vehicles. While a letter of "no objections to the adoption of electric vehicles or clean energy within the Loop for the purpose of this EIA study" is mentioned (Sec. 3.5.10), this is not a legally binding guarantee. If this assumption proves incorrect, the predicted NO₂ and PM concentrations could be significantly underestimated.
3. The construction phase assessment is almost entirely qualitative. Given that column installation for the viaduct could be as close as 14m to an Air Sensitive Receiver (ASR) and that approximately 100,700m³ of sediment will be excavated (Sec. 3.7.1), a quantitative screening assessment for dust and an odour impact assessment should have been provided.
4. The EIA excludes two major point sources (K. Wah Asphalt Plant and OPARK2) from dispersion modeling based on a qualitative assumption of terrain obstruction (Sec. 3.5.11). This exclusion is not sufficiently justified with quantitative evidence. In view that easterly prevailing winds and existence of low-level temperature inversion are frequent in Hong Kong, the plume of effluent from the stacks of these two major point sources may reach the Project area by "reflection" from temperature inversion above the terrain obstruction.
5. The conclusion that modeled NO₂ exceedance zones near the underpass openings have "no planned or existing ASRs" is short-sighted (Sec. 3.7.10). A formal recommendation should be made to planning authorities to prevent future sensitive development within or near these zones.
Noise
6. The construction noise assessment is entirely qualitative, despite the identification of Noise Sensitive Receivers (NSRs) located as close as <5m from the works (Sec. 4.7.4). The reliance on a future Construction Noise Management Plan (CNMP) to address all specifics creates significant uncertainty and risks inadequate protection for nearby residents.
7. The EIA defers critical details of acoustic windows/balconies for the planned residential developments (Res 6) to a future developer (Sec. 4.8.14). Indicative design specifications should have been provided to demonstrate technical feasibility without compromising indoor air quality.
8. The assessment correctly identifies several NSRs where overall noise levels exceed criteria, but the Project Road’s contribution is less than 1.0 dB(A). The responsibility for mitigation is vaguely passed to other project proponents. This must be explicitly linked to legally binding mechanisms through their respective statutory processes.
Water Quality
9. The assessment of the temporary diversion of Ping Hang Stream is inadequate (Sec. 5.6.11). It lacks a detailed, site-specific plan and fails to address the risk to aquatic fauna of conservation importance, such as the freshwater crab Somanniathelphusa zanklon (Sec. 8.6.37) A detailed Aquatic Fauna Translocation Plan must be required.
10. The EIA relies on qualitative statements like "localized and transient" for potential sediment release during works in the LMC Meander (Sec. 5.6.5). Simple quantitative estimates for worst-case scenarios, such as cofferdam failure, should have been included to provide a rational basis for designing mitigation measures.
11. The Emergency Response Plan (ERP) is described only at general context (Sec. 5.3.34 & 5.3.35). Given the sensitivity of the Deep Bay catchment, the EIA should mandate a site-specific ERP with detailed risk assessments, response protocols, and on-site resource lists.
Waste Management
12. The waste management assessment relies on sediment quality data from 2013 for the old meander (Sec. 6.6.15) and makes optimistic, untested assumptions about the lack of contamination in other areas. As the area around the Project site is notorious for flytipping for decades, a comprehensive pre-construction sediment sampling and testing plan for all excavation areas must be mandated to protect the public health, water quality and ecology.
13. The effectiveness to treat and reuse all 100,700m³ of excavated sediment on-site via cement stabilisation/solidification (S/S) (Sec. 6.6.22) should be proven. The EIA lacks site-specific treatability studies to demonstrate that the proposed method will consistently achieve acceptance criteria for the entire heterogeneous volume. A formal contingency plan for sediment that fails treatment is required.
14. Mitigation measures against fly-tipping are presented as recommendations rather than firm, auditable requirements (Sec. 6.7.4). The EIA should mandate GPS tracking on all waste vehicles and specify minimum standards for CCTV and signage to combat illegal dumping in this rural area. Control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles from engaging in illegal dumping activities. The mitigation measures to prevent illegal and environmentally vandalistic dumping of wastes generated from the Project should also be incorporated into the specifications of the works contract.
Land Contamination
15. The chapter’s conclusion that "no land contamination impact arising from the Project is anticipated" (Sec. 7.6.5) is premature and not supported by the evidence presented, which includes a potentially contaminated site (MTL-001) (Sec. 7.10.1), a history of arsenic contamination within the Loop, and naturally occurring elevated arsenic in the region (Sec. 7.5.20). The conclusion should accurately reflect the potential for impact and frame the recommended further works as a pre-condition for development.
16. The assessment's "clean bill of health" for the Loop's arsenic is misleading, as the previous investigation was only to a depth of 5m (Sec. 7.5.11), while the current project involves deep excavation well beyond that. Targeted deep sampling within the Loop’s excavation footprint is required to verify that no residual or deep-seated contamination remains.
Ecology
17. The mitigation strategy relies heavily on Off-site Wetland Compensation Areas (OWCAs) created for the original LMC Loop project. The EIA lacks a definitive statement or formal agreement with AFCD confirming that the additional ecological “debt” incurred by the ECR project is formally allocated and funded for management in perpetuity.
18. While the EIA acknowledges the critical importance of the area for Eurasian Otters, the proposed mitigation (wildlife crossings) is somewhat generic. The design of the temporary and permanent crossings should be explicitly reviewed against best-practice guidelines for Eurasian Otter, with specifications on dimensions, substrate, and lighting.
19. The woodland compensation is proposed at a 1:1 ratio, but the success of creating woodland on a site that currently supports grassland/shrubland is not guaranteed. Woodland replantation on wetlands should be avoided. The required Woodland Compensation Plan must include long-term success criteria, management, and monitoring to guarantee an adequate compensation.
20. The EIA does not consider the long-term impacts of climate change on the proposed mitigation measures, such as the viability of freshwater wetland enhancements in Area 4 under scenarios of more intense wet-season flows and potential saltwater intrusion.
Fisheries
21. The fisheries assessment underestimates the significance of the impact on Pond 36. It was observed to be active during recent site checks, yet the assessment attempts to minimize its value based on historical inactivity. The impact should be evaluated based on its current status as an active pond.
22. The assessment fails to adequately assess the risk to the 71 active fishponds adjacent to the construction works. A qualitative risk assessment for construction impacts (e.g., turbidity, bund stability) on these most sensitive receptors should have been included.
23. The cumulative impact assessment ignores the potential effects of the concurrent "Ma Tso Lung Area" project on the local fisheries support industry and social fabric.
Landscape and Visual
24. The cumulative visual impact with the planned "Northern Metropolis Highway - Kwu Tung Section" is dismissed based on phasing, ignoring the combined operational effect. A qualitative assessment of the combined visual impact from elevated viewpoints should have been included.
Environmental Monitoring and Audit (EM&A) Manual
25. The EM&A Manual critically defers all details for construction noise monitoring to a future CNMP (Sec. 12.3.1). The manual must include at least a framework with tentative monitoring locations, methodology, and a requirement for the CNMP to be approved before construction commences.
26. The manual fails to adequately track "conditional approvals" from the EIA. It should include a section listing all pre-construction plans (e.g., Woodland Compensation Plan, CAP) with clear submission deadlines and "hold points" preventing relevant works until approval.
27. The manual lacks an auditable requirement for GPS tracking of waste vehicles, a key measure to prevent fly-tipping. It should mandate that the Environmental Team review GPS logs weekly and report discrepancies.
28. The ecological monitoring lacks clear success criteria. For key mitigation measures like wildlife underpasses and woodland compensation, measurable targets should be defined to trigger remedial action if not met.
Thank you for your attention to these matters. We trust that these detailed comments will be taken into consideration in the further processing of the EIA Report. For any inquiries, please contact the undersigned (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk) at Green Power.
Green Power would like to draw your attention to our concerns and recommendations regarding the Environmental Impact Assessment (EIA) Report for the Development of the Loop – Eastern Connection Road (the Project). We have commented the Project Profile of the Project dated 22 May, 2025, and we would like to highlight and re-iterate several critical environmental issues that need to be addressed.
Public Consultation and Responsiveness
1. The project proponent's response to public concerns, as summarized in Table 2.4 of the EIA Report, consolidates comments into five broad categories and fails to directly address several key issues raised by Green Power in our submission on the Project Profile. Specific concerns regarding land use compatibility with "Conservation Area" and "Wetland Conservation Area" zonings, prevention of fly-tipping, control of the works footprint, and impacts on hillfires and the planned Wetland Conservation Parks System are not notably addressed from the proponent’s summary and lack a corresponding direct response.
Air Quality
2. The Air Quality Impact Assessment (AQIA) relies heavily on the assumption that all road-based public transport serving the Loop will be zero-emission vehicles. While a letter of "no objections to the adoption of electric vehicles or clean energy within the Loop for the purpose of this EIA study" is mentioned (Sec. 3.5.10), this is not a legally binding guarantee. If this assumption proves incorrect, the predicted NO₂ and PM concentrations could be significantly underestimated.
3. The construction phase assessment is almost entirely qualitative. Given that column installation for the viaduct could be as close as 14m to an Air Sensitive Receiver (ASR) and that approximately 100,700m³ of sediment will be excavated (Sec. 3.7.1), a quantitative screening assessment for dust and an odour impact assessment should have been provided.
4. The EIA excludes two major point sources (K. Wah Asphalt Plant and OPARK2) from dispersion modeling based on a qualitative assumption of terrain obstruction (Sec. 3.5.11). This exclusion is not sufficiently justified with quantitative evidence. In view that easterly prevailing winds and existence of low-level temperature inversion are frequent in Hong Kong, the plume of effluent from the stacks of these two major point sources may reach the Project area by "reflection" from temperature inversion above the terrain obstruction.
5. The conclusion that modeled NO₂ exceedance zones near the underpass openings have "no planned or existing ASRs" is short-sighted (Sec. 3.7.10). A formal recommendation should be made to planning authorities to prevent future sensitive development within or near these zones.
Noise
6. The construction noise assessment is entirely qualitative, despite the identification of Noise Sensitive Receivers (NSRs) located as close as <5m from the works (Sec. 4.7.4). The reliance on a future Construction Noise Management Plan (CNMP) to address all specifics creates significant uncertainty and risks inadequate protection for nearby residents.
7. The EIA defers critical details of acoustic windows/balconies for the planned residential developments (Res 6) to a future developer (Sec. 4.8.14). Indicative design specifications should have been provided to demonstrate technical feasibility without compromising indoor air quality.
8. The assessment correctly identifies several NSRs where overall noise levels exceed criteria, but the Project Road’s contribution is less than 1.0 dB(A). The responsibility for mitigation is vaguely passed to other project proponents. This must be explicitly linked to legally binding mechanisms through their respective statutory processes.
Water Quality
9. The assessment of the temporary diversion of Ping Hang Stream is inadequate (Sec. 5.6.11). It lacks a detailed, site-specific plan and fails to address the risk to aquatic fauna of conservation importance, such as the freshwater crab Somanniathelphusa zanklon (Sec. 8.6.37) A detailed Aquatic Fauna Translocation Plan must be required.
10. The EIA relies on qualitative statements like "localized and transient" for potential sediment release during works in the LMC Meander (Sec. 5.6.5). Simple quantitative estimates for worst-case scenarios, such as cofferdam failure, should have been included to provide a rational basis for designing mitigation measures.
11. The Emergency Response Plan (ERP) is described only at general context (Sec. 5.3.34 & 5.3.35). Given the sensitivity of the Deep Bay catchment, the EIA should mandate a site-specific ERP with detailed risk assessments, response protocols, and on-site resource lists.
Waste Management
12. The waste management assessment relies on sediment quality data from 2013 for the old meander (Sec. 6.6.15) and makes optimistic, untested assumptions about the lack of contamination in other areas. As the area around the Project site is notorious for flytipping for decades, a comprehensive pre-construction sediment sampling and testing plan for all excavation areas must be mandated to protect the public health, water quality and ecology.
13. The effectiveness to treat and reuse all 100,700m³ of excavated sediment on-site via cement stabilisation/solidification (S/S) (Sec. 6.6.22) should be proven. The EIA lacks site-specific treatability studies to demonstrate that the proposed method will consistently achieve acceptance criteria for the entire heterogeneous volume. A formal contingency plan for sediment that fails treatment is required.
14. Mitigation measures against fly-tipping are presented as recommendations rather than firm, auditable requirements (Sec. 6.7.4). The EIA should mandate GPS tracking on all waste vehicles and specify minimum standards for CCTV and signage to combat illegal dumping in this rural area. Control of vehicle activities should be strictly implemented through alarm and penalty systems to deter vehicles from engaging in illegal dumping activities. The mitigation measures to prevent illegal and environmentally vandalistic dumping of wastes generated from the Project should also be incorporated into the specifications of the works contract.
Land Contamination
15. The chapter’s conclusion that "no land contamination impact arising from the Project is anticipated" (Sec. 7.6.5) is premature and not supported by the evidence presented, which includes a potentially contaminated site (MTL-001) (Sec. 7.10.1), a history of arsenic contamination within the Loop, and naturally occurring elevated arsenic in the region (Sec. 7.5.20). The conclusion should accurately reflect the potential for impact and frame the recommended further works as a pre-condition for development.
16. The assessment's "clean bill of health" for the Loop's arsenic is misleading, as the previous investigation was only to a depth of 5m (Sec. 7.5.11), while the current project involves deep excavation well beyond that. Targeted deep sampling within the Loop’s excavation footprint is required to verify that no residual or deep-seated contamination remains.
Ecology
17. The mitigation strategy relies heavily on Off-site Wetland Compensation Areas (OWCAs) created for the original LMC Loop project. The EIA lacks a definitive statement or formal agreement with AFCD confirming that the additional ecological “debt” incurred by the ECR project is formally allocated and funded for management in perpetuity.
18. While the EIA acknowledges the critical importance of the area for Eurasian Otters, the proposed mitigation (wildlife crossings) is somewhat generic. The design of the temporary and permanent crossings should be explicitly reviewed against best-practice guidelines for Eurasian Otter, with specifications on dimensions, substrate, and lighting.
19. The woodland compensation is proposed at a 1:1 ratio, but the success of creating woodland on a site that currently supports grassland/shrubland is not guaranteed. Woodland replantation on wetlands should be avoided. The required Woodland Compensation Plan must include long-term success criteria, management, and monitoring to guarantee an adequate compensation.
20. The EIA does not consider the long-term impacts of climate change on the proposed mitigation measures, such as the viability of freshwater wetland enhancements in Area 4 under scenarios of more intense wet-season flows and potential saltwater intrusion.
Fisheries
21. The fisheries assessment underestimates the significance of the impact on Pond 36. It was observed to be active during recent site checks, yet the assessment attempts to minimize its value based on historical inactivity. The impact should be evaluated based on its current status as an active pond.
22. The assessment fails to adequately assess the risk to the 71 active fishponds adjacent to the construction works. A qualitative risk assessment for construction impacts (e.g., turbidity, bund stability) on these most sensitive receptors should have been included.
23. The cumulative impact assessment ignores the potential effects of the concurrent "Ma Tso Lung Area" project on the local fisheries support industry and social fabric.
Landscape and Visual
24. The cumulative visual impact with the planned "Northern Metropolis Highway - Kwu Tung Section" is dismissed based on phasing, ignoring the combined operational effect. A qualitative assessment of the combined visual impact from elevated viewpoints should have been included.
Environmental Monitoring and Audit (EM&A) Manual
25. The EM&A Manual critically defers all details for construction noise monitoring to a future CNMP (Sec. 12.3.1). The manual must include at least a framework with tentative monitoring locations, methodology, and a requirement for the CNMP to be approved before construction commences.
26. The manual fails to adequately track "conditional approvals" from the EIA. It should include a section listing all pre-construction plans (e.g., Woodland Compensation Plan, CAP) with clear submission deadlines and "hold points" preventing relevant works until approval.
27. The manual lacks an auditable requirement for GPS tracking of waste vehicles, a key measure to prevent fly-tipping. It should mandate that the Environmental Team review GPS logs weekly and report discrepancies.
28. The ecological monitoring lacks clear success criteria. For key mitigation measures like wildlife underpasses and woodland compensation, measurable targets should be defined to trigger remedial action if not met.
Thank you for your attention to these matters. We trust that these detailed comments will be taken into consideration in the further processing of the EIA Report. For any inquiries, please contact the undersigned (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk) at Green Power.
Yours faithfully,
CHENG Luk-ki
GREEN POWER
Yours faithfully,
CHENG Luk-ki
GREEN POWER
