Policy Comments & Advocacy

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

Water Quality

1. As Ma Liu Shui (MLS) Reclamation (the Project) site is adjoining Shing Mun River mouth, the project should not cause water pollution, odour nuisance and/or sedimentation in Shing Mun River channel.

2. All runoffs arising from the Project site during construction and operation phase should be properly collected and treated to avoid impacts on water quality of Shing Mun River and Tolo Harbour/Channel.

3. In addition to the Project, the alignment of submarine pipe of Tolo Harbour Effluent Export Scheme (THEES) should be re-provided with consideration of Sha Tin Sewage Treatment Works (STSTW) relocation to caverns.

4. The project should not deteriorate the water quality of effluent under THEES which is discharged to Kai Tak River. Therefore, the Project should not cause pollution, odour nuisance and/or sedimentation of Kai Tak River.

5. Kai Tak River and Shing Mun River should be identified as Water Sensitive Receiver(WSR) and Visually Sensitive Receiver because both river channels are prone to the water quality and visual impacts of the Project that affects the residents along these two rivers.

6. The location of reprovisioned emergency submarine outfall of STSTW should minimize the water quality impacts on Shing Mun River Water channel and mariculture zones due to release of untreated effluents into the nearby water bodies.

7. The location of other WSRs, especially ecologically sensitive sites and mariculture zones should also be identified by hydrodynamic and water quality modelling.

Ecology

8. All runoffs arising from the construction site should be properly collected and treated to avoid impacts on the ecology and mariculture zones in Tolo Harbour/Channel and ecologically sensitive sites.

9. Ecological impact assessment should be conducted for permanent habitat loss, habitat fragmentation and change of water flow hydrodynamic regime, water quality, erosion and sedimentation patterns due to reclamation and associated proposed landuse.

10. Ecological enhancement should be provided for the re-constructed seawalls of the Project.

Waste

11. The navigation route of barges transporting any sediment dredged should be closely and effectively monitored to prevent dumping at sea.

12. Treatment of any contaminated sediment dredge at temporary locations in the vicinity of the Project should not discharge any water pollutants to Tolo Harbour water.

13. Stringent documentation, verification and monitoring for the waste disposal system must be implemented to avoid landfilling in rural areas by waste and C&D materials generated by the Project, especially SSSI in Ting Kok, wetlands in Tung Tsz, farmlands in Lam Tsuen and other rural areas in Tai Po, Ma On Shan, Sai Sha Road and along the transportation routes.

14. Reused fill materials should be used for the reclamation work of the Project.

Integrity of the Project

15. If non-dredged method is adopted for the statutory EIA process for the Project, change of construction method should render any completed statutory EIA procedures invalid. Detailed study or assessment should be re-conducted to ensure the accuracy of impact assessments, especially the ecological impacts assessment and hydrodynamic and water quality modelling.

16. Proposed land use development and associated infrastructure on the MLS reclamation site should not be divided into separated projects to shrink from the statutory requirement of conducting EIA under EIAO ordinance.

17. EIA for reprovisioning / modification works associated with the land-based facilities affected by the proposed reclamation listed in Table 1.1 of PP should be conducted and included in EIA Report of the Project, as those works are initiated by the Project and/or located in the Project site.

18. The proposed land use and transportation network of the Project should be finalized as a valid basis for EIA under Environmental Impact Assessment Ordinance.

19. Cumulative environmental and ecological impacts should be conducted for reclamation site at Ma Liu Shui together with the development of Sha Tin Sewage Treatment Works (STSTW) after relocation to caverns for medium to long term development.

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).