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 Northern Metropolis Highway – San Tin Section (the Project). We have commented on the Project Profile of the Project dated 6 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 our comments on the Project Profile, as summarized in Table 2.6 of the EIA Report, addresses several initial concerns such as the 12-month ecological surveys and the Cultural Heritage Impact Assessment. However, specific recommendations regarding a "zero discharge policy" for Deep Bay, transport-led air quality policies, and explicit "zero-waste" targets remain partially addressed or omitted from the proponent’s summary and lack a corresponding direct commitment.
Air Quality
2. Emission Source Control: While the report identifies construction dust and operational traffic as key sources, there should be a stronger commitment to using electric construction plant and vehicles to minimize local pollutant emissions.
3. Proximity to Sensitive Receivers: The assessment identifies numerous residential areas and schools as sensitive receivers; we recommend enhanced dust suppression (e.g., higher frequency of watering) beyond standard requirements in these high-risk zones.
4. Cumulative Impacts: The report must ensure that air quality modeling fully accounts for the concurrent construction of the San Tin Technopole and Northern Link, as the overlap of these major projects could lead to significant exceedances of Air Quality Objectives (AQOs).
5. Ozone Pollution: According to Environmental Protection Department's yearly Air Quality and Health Index (AQHI) data, Northern District and Yuen Long have consistently ranked as the most polluted districts in terms of high health risk hours and days mainly due to ozone. The Project area lies in close proximity to both. Strategies to suppress ozone formation and health impacts should be formulated.
Noise
6. Noise Barrier Aesthetics: The extensive use of noise barriers and semi-enclosures should be designed with bird-friendly materials (e.g., non-reflective or patterned glass) to prevent bird collisions in the Project area which is close/adjacent to foraging grounds of birds, such as Lam Tsuen Country Park and countryside along the Project alignment.
7. Low-Noise Road Surfacing (LNRS): We recommend to consider the mandatory application of LNRS for all high-speed sections to reduce operational noise at the source, rather than relying solely on vertical barriers.
8. Night-time Construction: The report should strictly prohibit high-noise construction activities (e.g., percussive piling) during the night-time or early morning to protect the nesting and roosting behaviors of local wildlife.
Water Quality
9. Zero Discharge Principle: For works near the Deep Bay catchment, the proponent should explicitly commit to a "zero discharge" policy for construction runoff to protect the fragile Ramsar Site ecosystem.
10. Sustainable Drainage Systems (SuDS): We support the inclusion of SuDS but recommend the implementation of bioretention swales and rain gardens specifically designed to filter pollutants (e.g. heavy metals) and oils from road runoff before it enters the Kam Tin River and other watercourses.
11. Siltation Control: Stringent controls on silt curtains and cofferdams are required during the foundation works in Kam Tin River to prevent increased turbidity that could harm downstream habits.
Waste Management
12. Real-time GPS Tracking: We welcome the commitment to real-time GPS tracking for dump trucks to prevent illegal dumping in the Wetland Conservation Area (WCA) and ensure all C&D waste reaches designated facilities. In addition, "no-go" areas including areas such as countryside places, fish ponds and agricultural lands to protect those sensitive habitats must be designated. An instantaneous alarm system should be utilised that dump trucks will trigger the alarm system when they encroach these no-go areas. Penalty terms for deviation of vehicles from designated areas / routes or entering "no-go" areas should be clearly listed in relevant contracts for adequate control.
13. Waste Reduction Targets: The Waste Management Plan should set a quantifiable target for on-site recycling and reuse of inert C&D materials (e.g., 80%) to reduce the burden on public fills.
Land Contamination
14. Arsenic and Heavy Metals: We urge the proponent to conduct further site investigations specifically for arsenic and heavy metals at all vulnerable former agricultural and industrial lots before any earthworks commence to avoid pollution to ecologically sensitive areas and aquaculture operation.
15. Remediation Transparency: A detailed Remediation Action Plan (RAP) should be made public for any site found to have significant contamination, ensuring that the remediation process does not create secondary environmental impacts.
Ecology
16. Alignment: Taking into account of minimizing environmental and ecological impacts for the designating Project alignment is welcome. We stress that the Project alignment should provide feasibility for the other Northern Metropolis Highway sections connected to the Project to avoid encroachment and damages to ecologically sensitive/important areas and wildlife.
17. Bird Flight Corridors: The alignment must maintain clear flight paths for migratory birds; viaduct heights and pier placements should be optimized to avoid disrupting the movement of Ardeids between feeding and roosting sites.
18. Bat Roost Protection: The identified bat roost at Pok Wai requires a dedicated protection zone and a pre-construction survey to ensure no disturbance occurs during the breeding season.
19. Wetland Compensation: Any loss of "Wetland Conservation Area" or "Wetland Buffer Area" must be compensated with "like-for-like" high-quality habitats at a ratio of at least 1:1, ensuring no net loss of wetland function.
20. Country Park Encroachment: While the project aims to avoid Lam Tsuen Country Park (LTCP), any works near the boundary must utilize "quiet" construction methods to prevent disturbance to forest-dwelling species.
21. Hillfire Prevention: Large-scale destructive hillfire incidents frequently occur in Kai Kung Leng, part of LTCP. In order to protect the woodlands and habitats neigbouring the Project site, site regulations for hillfire prevention should be clearly stipulated in the specifications of the works contract, including forbidding open burning of domestic, C&D and yard wastes, no smoking, no food cooking, etc. within and outside Project sites and country park areas. Portable firefighting equipment should be installed in the Project sites, especially in vicinity of vegetated areas.
22. River/Stream Water Quality: The run-off and drainage from the construction sites of the Project should not be discharged to the nearby watercourses. Sewage, sludge and wastewater generated from construction sites should be fully collected and carried away from the Project site. Sediments, soil, excavated materials should not be stockpiled near to the streams or water channels to avoid washing down to water bodies during rainstorms. 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.
Landscape and Visual Impact
23. Viaduct Camouflage: Aboveground structures should use earth-toned finishes and vertical greening to blend into the natural backdrop of Kai Kung Leng/LTCP and the wetland landscape.
24. Tree Compensation: We recommend a tree compensation ratio more than 1:1 using native species to enhance local biodiversity and provide better visual screening.
Hazard to Life
25. Explosives Transport: The transport of explosives to the Tai Shu Ha magazine must avoid peak traffic hours and ecologically sensitive routes.
Environmental Monitoring and Audit (EM&A) Programme
26. Reporting Transparency: Monthly EM&A reports should be publicly accessible on a dedicated project website within two weeks of the reporting period to ensure community and NGO oversight.
27. Event and Action Plans: Action plans for water quality should include immediate siltation source identification to prevent long-term damage to the Deep Bay ecosystem.
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 Northern Metropolis Highway – San Tin Section (the Project). We have commented on the Project Profile of the Project dated 6 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 our comments on the Project Profile, as summarized in Table 2.6 of the EIA Report, addresses several initial concerns such as the 12-month ecological surveys and the Cultural Heritage Impact Assessment. However, specific recommendations regarding a "zero discharge policy" for Deep Bay, transport-led air quality policies, and explicit "zero-waste" targets remain partially addressed or omitted from the proponent’s summary and lack a corresponding direct commitment.
Air Quality
2. Emission Source Control: While the report identifies construction dust and operational traffic as key sources, there should be a stronger commitment to using electric construction plant and vehicles to minimize local pollutant emissions.
3. Proximity to Sensitive Receivers: The assessment identifies numerous residential areas and schools as sensitive receivers; we recommend enhanced dust suppression (e.g., higher frequency of watering) beyond standard requirements in these high-risk zones.
4. Cumulative Impacts: The report must ensure that air quality modeling fully accounts for the concurrent construction of the San Tin Technopole and Northern Link, as the overlap of these major projects could lead to significant exceedances of Air Quality Objectives (AQOs).
5. Ozone Pollution: According to Environmental Protection Department's yearly Air Quality and Health Index (AQHI) data, Northern District and Yuen Long have consistently ranked as the most polluted districts in terms of high health risk hours and days mainly due to ozone. The Project area lies in close proximity to both. Strategies to suppress ozone formation and health impacts should be formulated.
Noise
6. Noise Barrier Aesthetics: The extensive use of noise barriers and semi-enclosures should be designed with bird-friendly materials (e.g., non-reflective or patterned glass) to prevent bird collisions in the Project area which is close/adjacent to foraging grounds of birds, such as Lam Tsuen Country Park and countryside along the Project alignment.
7. Low-Noise Road Surfacing (LNRS): We recommend to consider the mandatory application of LNRS for all high-speed sections to reduce operational noise at the source, rather than relying solely on vertical barriers.
8. Night-time Construction: The report should strictly prohibit high-noise construction activities (e.g., percussive piling) during the night-time or early morning to protect the nesting and roosting behaviors of local wildlife.
Water Quality
9. Zero Discharge Principle: For works near the Deep Bay catchment, the proponent should explicitly commit to a "zero discharge" policy for construction runoff to protect the fragile Ramsar Site ecosystem.
10. Sustainable Drainage Systems (SuDS): We support the inclusion of SuDS but recommend the implementation of bioretention swales and rain gardens specifically designed to filter pollutants (e.g. heavy metals) and oils from road runoff before it enters the Kam Tin River and other watercourses.
11. Siltation Control: Stringent controls on silt curtains and cofferdams are required during the foundation works in Kam Tin River to prevent increased turbidity that could harm downstream habits.
Waste Management
12. Real-time GPS Tracking: We welcome the commitment to real-time GPS tracking for dump trucks to prevent illegal dumping in the Wetland Conservation Area (WCA) and ensure all C&D waste reaches designated facilities. In addition, "no-go" areas including areas such as countryside places, fish ponds and agricultural lands to protect those sensitive habitats must be designated. An instantaneous alarm system should be utilised that dump trucks will trigger the alarm system when they encroach these no-go areas. Penalty terms for deviation of vehicles from designated areas / routes or entering "no-go" areas should be clearly listed in relevant contracts for adequate control.
13. Waste Reduction Targets: The Waste Management Plan should set a quantifiable target for on-site recycling and reuse of inert C&D materials (e.g., 80%) to reduce the burden on public fills.
Land Contamination
14. Arsenic and Heavy Metals: We urge the proponent to conduct further site investigations specifically for arsenic and heavy metals at all vulnerable former agricultural and industrial lots before any earthworks commence to avoid pollution to ecologically sensitive areas and aquaculture operation.
15. Remediation Transparency: A detailed Remediation Action Plan (RAP) should be made public for any site found to have significant contamination, ensuring that the remediation process does not create secondary environmental impacts.
Ecology
16. Alignment: Taking into account of minimizing environmental and ecological impacts for the designating Project alignment is welcome. We stress that the Project alignment should provide feasibility for the other Northern Metropolis Highway sections connected to the Project to avoid encroachment and damages to ecologically sensitive/important areas and wildlife.
17. Bird Flight Corridors: The alignment must maintain clear flight paths for migratory birds; viaduct heights and pier placements should be optimized to avoid disrupting the movement of Ardeids between feeding and roosting sites.
18. Bat Roost Protection: The identified bat roost at Pok Wai requires a dedicated protection zone and a pre-construction survey to ensure no disturbance occurs during the breeding season.
19. Wetland Compensation: Any loss of "Wetland Conservation Area" or "Wetland Buffer Area" must be compensated with "like-for-like" high-quality habitats at a ratio of at least 1:1, ensuring no net loss of wetland function.
20. Country Park Encroachment: While the project aims to avoid Lam Tsuen Country Park (LTCP), any works near the boundary must utilize "quiet" construction methods to prevent disturbance to forest-dwelling species.
21. Hillfire Prevention: Large-scale destructive hillfire incidents frequently occur in Kai Kung Leng, part of LTCP. In order to protect the woodlands and habitats neigbouring the Project site, site regulations for hillfire prevention should be clearly stipulated in the specifications of the works contract, including forbidding open burning of domestic, C&D and yard wastes, no smoking, no food cooking, etc. within and outside Project sites and country park areas. Portable firefighting equipment should be installed in the Project sites, especially in vicinity of vegetated areas.
22. River/Stream Water Quality: The run-off and drainage from the construction sites of the Project should not be discharged to the nearby watercourses. Sewage, sludge and wastewater generated from construction sites should be fully collected and carried away from the Project site. Sediments, soil, excavated materials should not be stockpiled near to the streams or water channels to avoid washing down to water bodies during rainstorms. 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.
Landscape and Visual Impact
23. Viaduct Camouflage: Aboveground structures should use earth-toned finishes and vertical greening to blend into the natural backdrop of Kai Kung Leng/LTCP and the wetland landscape.
24. Tree Compensation: We recommend a tree compensation ratio more than 1:1 using native species to enhance local biodiversity and provide better visual screening.
Hazard to Life
25. Explosives Transport: The transport of explosives to the Tai Shu Ha magazine must avoid peak traffic hours and ecologically sensitive routes.
Environmental Monitoring and Audit (EM&A) Programme
26. Reporting Transparency: Monthly EM&A reports should be publicly accessible on a dedicated project website within two weeks of the reporting period to ensure community and NGO oversight.
27. Event and Action Plans: Action plans for water quality should include immediate siltation source identification to prevent long-term damage to the Deep Bay ecosystem.
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,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power
Yours faithfully,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power
