Policy Comments & Advocacy

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

Land Uses

1. The proposed development (the Project) is located within the globally important Inner Deep Bay wetland system. Any land uses in the Project should not compromise the ecological functions of the designated Wetland Conservation Area (WCA) and Wetland Buffer Area (WBA).

2. According to the statutory Ma Tso Lung and Hoo Hok Wai Outline Zoning Plan (Plan No. S/NE-MTL/3) and Kwu Tung North Outline Zoning Plan (Plan No. S/KTN/4), the Project comprises large area of “Green Belt” (GB) that is zoned 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 is likely against the land use of GB, and the loss of these natural features and ecological functions should be evaluated and mitigated.

3. In addition, a large piece of “Agriculture” (ARG) land around Ma Tso Lung San Tsuen and Ma Tso Lung Shun Yee San Tsuen will be affected by the Project. We opine that these farmlands are the precious agricultural flatland and wetland resources in the Northern Metropolis, therefore the existing farmlands and associated facilities such as irrigation system should be preserved as far as possible. Inactive farmlands revitalization can be incorporated in the Project to facilitate multiple functions such as ecological enhancement and carbon storage.

Cumulative Environmental Impacts

4. In light of the multiple developments proposed in the Northern Metropolis Development Strategy, it is doubtful if separate EIAs of these projects can accurately access their cumulative environmental impacts. We stress to assess all the potential cumulative environmental impacts in the EIA.

Ecology

5. The fishponds in Hoo Hok Wai and outside the Lok Ma Chau Loop are one of the major ecological sensitive receivers adjacent to the Project. The ecological impacts to these important wetlands induced by the Project should be fully assessed and mitigated. Provided that there will be a prominent increase in population in the Project Site, the road and footpath networks of the Project should be designed in a way that deters the people from entering these ecologically sensitive areas, especially the Wetland Conservation Parks.

6. In particular, the alignment of the proposed new road connecting the Lok Ma Chau Loop and Kwu Tung North New Development Area has not been mentioned in the PP. We opine that any intrusion of new road to the existing fishponds should be avoided as far as possible otherwise undesirable habitat fragmentation will be anticipated.

7. The Ma Tso Lung (seasonal) marsh is the significant habitat for dragonflies Rhodothemis rufa and Urothemis signata⁽¹⁾, an EcoIA for the marsh-dependent and aquatic species should be conducted throughout the wet season.

8. In addition, the Ma Tso Lung Stream and its tributaries are interconnected to the marshy habitats and Inner Deep Bay Ramsar Site, therefore alternation of the streams and hydraulics should be avoided. Sediments, soil, excavated materials should not be stockpiled near to the drainage system to avoid wash down to water bodies during rainstorms.

9. More importantly, the comprehensive ecological assessment should be conducted for Ma Tso Lung Stream and its ecological functions as foraging and breeding habitats for flora and fauna, connectivity between hilly terrestrial, lowland countryside and wetlands habitats, etc, should be adequately addressed with sufficient baseline data.

10. Blue-green infrastructure should not be considered as a proactive conservation measure to encroach any identified or potential important aquatic and riparian habitats. No river channels should be decked because decking of river/stream channels escalates flooding risk owing to the altered local precipitation pattern under climate change.

11. Aquatic, river course and riparian habitats should not be disturbed or encroached by works and associated activities such as discharge of effluent and runoff, stockpiling of materials, wastes and chemicals, vehicle parking, etc. There should be buffer areas on both riparian zones along streams and tributaries in the Project area to protect the water quality, ecology and landscape of the streams. Establishment of such buffer areas can avoid spillage of environmental impacts to Hoo Hok Wai Wetland Conservation Park through the drainage system/streams in Project area.

12. The project proponent should avoid bird collision on glass wall by avoiding the use of large-sized transparent or highly reflective glass surface in infrastructures, or taking proper preventive measures, such as applying patterns or stickers on the glass, installing bird deterrent devices or screens, or adjusting the reflectivity or transparency of the glass.

13. Glare impacts from lighting of the proposed project on surrounding areas and wildlife should be minimized, if unavoidable, by adjusting the light intensity and illumination angles.

14. It is recommended to select native tree species for the compensatory tree planting. Post-planting and post-transplanting monitoring and care should be taken place accordingly.

15. Effective and enforceable measures to prevent hillfires should be proposed for both construction and operation phases.

Wastewater

16. 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 operational phase should be prevented from discharging into Ma Tso Lung Stream or its tributaries.

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

Solid waste

18. As most of the areas adjoining the Project site are rural area, any fly-tipping of solid wastes 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.

19. We suggest the tracking and monitoring of transport vehicle routes through GPS systems, and opine that 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 (e.g. the ticket-trip system) should also be incorporated into the specifications of the works contract.

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).