BY EMAIL ONLY
13
 
June 2024

Dr. CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)

cc.
Dear Dr. Chui,
就「龍鼓灘填海」工程項目簡介表達意見(只有英文)
Project Profile for Reclamation at Lung Kwu Tan

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

1. The potential reclamation extent of the proposed Project is about 145 ha at Lung Kwu Tan (LKT), covering the bay area at the north of LKT and a few patches of existing lands along the coast. It abuts Black Point headland in the north, industrial/ brownfield sites in the east, village settlements including Pak Long and Sha Po Kong in the southeast, as well as Urmston Road from south to north.

2. Green Power is gravely concerned the need of the Project in view that no recommended land use is designated for the lands formed by reclamation.

3. The southern part of proposed reclamation has insurmountable visual impact on LKT bay adjacent to Tap Shek Kok and alters the hydraulics of the bay that will impair the ecology and deteriorate water quality of the bay. Also, dredging works will seriously pollute the water quality and worsen the adverse impacts.

4. Regarding the transportation of dredged and fill materials to and from the Project site, both roads and marine vessel options will generate environmental, ecological and traffic impacts, particularly the emission of air pollutants from marine vessels/barges and heavy vehicles. Current traffic of Lung Kwu Tan Road is busy as it is the only vehicle access for the facilities in Tsang Tsui, e.g. WENT, T·Park, Y·Park, etc, Traffic congestion of Lung Kwu Tan Road will be caused and worsened by additional heavy vehicles associated with the Project that seriously affects the villages to east of Lung Kwu Tan Road.

5. For interfacing with the existing land, land-based works of the Project including site clearance and site formation works, etc. will also be required along the coastal areas adjacent to the proposed reclamation. Activities associated with the Project, e.g. materials piling and machinery storage, may encroach and/or disturb existing habitats outside the Project boundary.

6. Any works associated with possible rearrangement of submarine outfall at Urmston Road (subject to further investigation) will bring about the environmental and ecological impacts on Marine Parks and coastal habitats in western water.

7. The waters around the Black Point next to the Project site have been identified as the “hot spot” of Chinese White Dolphin where “dolphins regularly occurred in the past” (1), therefore dolphins should be the ecological sensitive receivers directly influenced by the increase of marine traffic induced by the Project. We are worried that the Project will further worsen the survival of Chinese White Dolphin which population is seriously threatened in recent years.

8. LKT is a habitat of endangered Horseshoe Crabs according to the local villagers. The project will cause loss of their shrinking local habitats.

9. LKT is one of the few butterfly hotspots in the western New Territories. At least three “Very Rare” butterflies have been recorded by Green Power (2), namely Hainan Palm Dart (Telicota besta), Common Leopard (Phalanta phalantha) and Silver Forget-me-not (Catochrysops panormus). Red Lacewing (Cethosia biblis) is a locally uncommon butterfly with frequent records in LKT and has been spotted in the Project sites. The Project will trigger further loss of butterfly habitats in LKT.

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).

Yours faithfully,

CHENG Luk Ki
Director, GREEN POWER

Yours faithfully,

CHENG Luk Ki
Director, GREEN POWER

二零二四年
六月
十三日

(1) Agriculture, Fisheries and Conservation Department (2023). Monitoring of Marine Mammals in Hong Kong Waters (2022-23) —Final report. Available from: https://www.afcd.gov.hk/tc_chi/conservation/con_mar/con_mar_chi/con_mar_chi_chi/files/Final_Report_2022to23.pdf

(2) Green Power’s press release, The Latest “Butterfly Survey Results” (15 Oct, 2023):
https://download.greenpower.org.hk/butterfly/press/20231015_e.pdf