Policy Comments & Advocacy

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

Ecology and Landuse Compatibility

1. The Project Site partly falls within fishponds and wetlands of ecological importance which are under various zonings including the “Conservation Area” (“CA”), “Conservation Area (1)” “CA(1)”, “Green Belt” (“GB”) and “Other Specified Uses “OU” annotated “Other Specified Uses (Ecological Area)” (“OU(EA)”) on the approved Lok Ma Chau Loop Outline Zoning Plan (OZP) No. S/LMCL/2, the approved San Tin OZP No. S/YL-ST/8 and the approved Ma Tso Lung and Hoo Hok Wai OZP No. S/NE-MTL/3. Furthermore, the Project Site falls within or is located near Deep Bay Wetland Outside Ramsar Site, Wetland Conservation Area (WCA) or Wetland Buffer Area (WBA), and mitigation wetlands and woodland. The strip of wetland sandwiched between the Loop and Lok Ma Chau, may serve as a key link between Hoo Hok Wai and Mai Po/San Tin wetlands for birds and other wildlife (Sec. 4.5.1).

2. In view of the global, regional and local ecological importance of habitats adjoining the Project Site, the Project should not compromise the ecological functions of the wetlands, especially the Inner Deep Bay Ramsar Site and its associated Wetland Conservation Area (WCA) and Wetland Buffer Area (WBA). Any intrusion or encroachment of such ecological sensitive habitats should be strictly avoided in the first place. The ecological impacts induced from the Project should be fully assessed and mitigated with accurate and updated environmental and ecological data/information, if loss of or disturbance to other habitats is unavoidably resulted. Past data of previous studies/EIA reports should be validated in prior to being reused for the EIA report of the Project.

Alternative Options

3. Alternative options for the Project should be comprehensively considered and assessed. The preferred option should deter the vehicular access from entering surrounding ecologically sensitive areas with proper alignments and locations of trunk/major road(s), feeder roads and road conjunctions to prevent ecological impacts, uncontrollable waste dumping and proliferation of brownfield.

Confining the Works Footprint

4. The works boundary of the Project should not occupy, encroach or disturb the ecologically sensitive areas mentioned in point 1 by works agents including but not limited to contractors, subcontractors, suppliers and associated service providers for related uses such as site offices, material/equipment/machinery installation and storage, stock piling, carparks, canteens, etc. Works boundary should be clearly delineated and physically fenced to prevent trespassing by project personnel to neighbouring ecologically sensitive areas.

Prevention of Water Pollution and Flooding

5. The Project area is located within the watershed which feeds 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 point source and non-point source pollution and site surface runoff generated from the Project site during both construction and operation phase should be prevented from discharging into neighbouring river channels and stormwater drainage directly, and any discharge to fishponds and wetlands should be prohibited. We proposed that related mitigation measures should be incorporated into the specifications of the works contract.

6. As the surrounding areas of the Project Site is low lying and prone to flooding, the Project should not alter or obtruct of surface runoff pathways that leads to flooding during heavy rainstorms in neighbouring areas.

7. Decking of natural or manmade channels, that render pollution control for channels inefficient or technically problematic and increase the flooding risk upstream, should be prohibited.

Destruction of Wetlands

8. The amount of solid wastes, such as C&D wastes, soil and rocks, generated from the proposed project has not been mentioned in the PP. As most of the areas adjoining the Project Site are countryside places and fishponds, any fly-tipping of such solid wastes generated from this project will be hard to combat. Therefore, fly-tipping and illegal dumping induced by the Project should be strictly prohibited during the construction phase because the areas around the Project Sites are notorious for destruction of ecological sensitive sites by massive dumping of wastes and debris.

9. Regrettably even if such incidents are spotted, restoration of filled farmlands, fishponds or wetlands are non-enforceable, inefficient, or impractical in most cases because of various reasons such as land ownership, landuse zoning and etc. Irreversible loss of recognized and valuable habitats has been resulted in past decades in areas adjoining the Project Site. Therefore, generation, transportation and disposal of such solid wastes should be under stricter control. The mitigation measures to prevent illegal and environmentally vandalistic dumping of wastes generated from the proposed Project should be incorporated into the specifications of the works contract.

Ecological Threats

10. Road kill of wild animals and bird collision caused by noise barriers should be avoided with sound and effective construction design. Animal passage across the roads must be properly designed to address the potential impacts on terrestrial, amphibious and aquatic fauna. Target species served by the animal passage should include Eurasian Otter (Lutra lutra). The animal passage should avoid human disturbance, properly concealed and well connected to existing, known and potential habitats of target species.

11. The Project should not impose major impacts on functions, quality and operation of the planned Wetland Conservation Parks System. The Project also should not fragment the contiguous habitats in the Northwest New Territories, particularly ecological continuity between Mai Po/San Tin and Ma Tso Lung/Hoo Hok Wai.

Sustainable Transport

12. The Project Site 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 2023, 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 eight consecutive years. On the other hand, AQHI records of Northern has also been among the worst since its air quality monitoring station was established in 2020.

13. Environmentally Friendly Transport modes/Systems or low carbon/emission transport modes should be considered to improve the air quality and reduce carbon emission

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).