Policy Comments & Advocacy

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

Land Uses

1. The captioned proposed development (the Project) is located close to the globally important Mai Po wetland system. Any land uses in the Project area should not compromise the ecological values and functions of the wetlands, especially the Inner Deep Bay Ramsar Site and its associated Wetland Conservation Area (WCA) and Wetland Buffer Area (WBA). Particularly, high-rise buildings are definitely incompatible with the surrounding rural landscape and may possibly block the flight paths of the avifauna.

2. According to the statutory Ngau Tam Mei Outline Zoning Plan (Plan No. S/YL-NTM/12), about one fourth of the Project area is zoned as the “Green Belt” (“GB”) in which “the planning intention of this zone is primarily for defining the limits of urban and sub-urban development areas by natural features and to contain urban sprawl as well as to provide passive recreational outlets. There is a general presumption against development within this zone”. The Project violates the land use of ”GB”, and the potential loss of these natural features and ecological functions should be evaluated and mitigated.

3. “The Project of about 129 ha comprises public and private housing, government, institution and community (GIC) facilities, as well as the associated infrastructure works (e.g. road networks, sewage pumping stations, etc.)”(Section 1.2.4). However, the location, area and scale of these land uses, facilities and infrastructures have not provided in the PP that may lead to underestimation of associated environmental and ecological impacts. Thus, details of land uses such as location, area, scale, plot ratio, population, and planning and transport correlation to neighbouring areas should be provided as basis for EIA study.

4. As large area of habitats is expected to be lost to the Project, Lam Tseun Country Park should be considered to extend and cover the “Conservation Area” to the southern of the study area of the Project (i.e. Northwest slope of Kai Kung Leng) to halt further loss of habitats.

Brownfield Proliferation

5. A proper reallocation and/or compensation plan for the existing brownfield operations in the Project area should be formulated in the early stage to prevent proliferation of unfavorable and uncontrollable brownfields to the nearby rural areas that leads to further loss of habitats and degradation of rural area in the NWNT.

Cumulative Environmental Impacts

6. Given other major developments such as the San Tin Technopole and Northern Link interconnected with the Project, it is doubtful if separate EIAs of these projects can accurately access their cumulative environmental impacts. We stress including all the potential environmental impacts of the adjacent developments in the current EIA so that the cumulative environmental impacts will not be underestimated.

Air Quality

7. The proposed Project is in the Yuen Long District which is highly prone to air pollution. According to the EPD’s yearly average Air Quality and Health Index (AQHI) data from 2014 to 2022, Yuen Long ranked the top three most polluting districts in terms of the number of hours with AQHI ≥7 and days with daily maximum AQHI ≥7 in at least seven consecutive years.

8. Due to the current unsatisfactory air quality, the Project proponent should fully assess the (cumulative) air quality impacts and formulate effective mitigation measures to control the air pollution. In addition, certain polluting industrial/commercial activities should be forbidden in order not to worsen the air quality.

Wastewater

9. The Ngau Tam Mei Drainage Channel (NTMDC) within the proposed development is directly connected to the Mai Po Inner Deep Bay Ramsar Site. In order to comply with the “zero discharge policy” for Deep Bay and protect the ecology of Ramsar Site, any untreated surface runoff generated from the Project site during both construction and operation phase should be prevented from discharging into NTMDC or its tributaries, other natural or man-made channels, stormwater drainage and wetlands directly. We propose that related mitigation measures should be incorporated into the specifications of the works contract.

10. Moreover, a “sustainable urban drainage system” (similar to that planned in Tung Chung West New Twon Extension) should be seriously considered to incorporate into the Project to promote the climate resilience of the Project and treat the polluted surface runoff.

Solid Waste

11. As most of the areas adjoining the Project site are rural area, any fly-tipping of solid wastes generated from this project will be hard to combat. Even if such incidents are spotted, reinstatement can seldom be implemented because of various reasons such as land ownership, land use zoning and etc. Therefore, storage, transportation and disposal of such solid wastes should be under stricter monitoring and control. The mitigation measures to prevent illegal and environmentally vandalistic dumping of wastes generated from the proposed development should be incorporated into the specifications of the works contract.

12. Comprehensive recycling implementation plan and network in the Project site should be formulated to promote a zero-waste community (including the neighboring villages).

Ecology

13. The PP states: “Species of conservation  importance  including  various  flora,  avifauna,  butterfly, mammal and herpetofauna species are also recorded in low abundancies” (Section 3.7.1). The Project proponent should provide relevant sources in the PP to support this claim, and we opine that such a claim should not be made unless a comprehensive ecological study in the Project study area has been conducted. From an ecological perspective, species of conservation importance are commonly in higher rarity. The occurrence, though in low abundance, of them does not mean they are neglectable; instead, their existence already infers the significant ecological values of a place.

14. Given the high ecological sensitiveness around the Project site, year-long ecological surveys for diverse taxa groups and habitats should be conducted in the EIA study. Since the primary conservation targets of the nearby Inner Deep Bay Ramsar Site are the migratory birds, additional bird survey efforts should be invested during the migratory seasons to assess the ecological impacts on migratory birds.

15. The NTMDC should be identified as one of the ecologically sensitive receivers because it also serves as the foraging grounds for wetland birds. The priority for proposed river revitalization of NTMDC should be nature conservation to carry out functions of wildlife habitats, ecological connection to Deep Bay wetlands, breeze corridor in addition to flood alleviation and greening.

16. The proposed retention lake and underground storage tanks should not affect the ecological, hydraulic and hydrological performance of nearby wetlands, rivers/streams and waterbodies in normal weather conditions. Contrarily, opportunities to enhance their ecological function should be sought through ecological design and well use of collected surface runoff.

17. Removal of trees and vegetation in the Project site should be avoided as far as possible in order to reduce ecological impact, loss of habitats and urban heat island effect. Any vegetation loss in the proposed project should be compensated through the cultivation of native plant species.

18. A prominent increase in population in the Project area is anticipated, therefore the road and footpath networks should be designed in a way that deters people from entering the ecologically sensitive areas.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 39610200, F: 2314 2661, Email: info@greenpower.org.hk).