Policy Comments & Advocacy

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

1. The proposed production caverns and main access tunnels in Lam Tei Quarry would encroach to the underground area of Tai Lam Country Park and natural watercourses. In view that granite bedrock is usually distributed densely with joints and may contain faults, the proposed project will potentially cause groundwater infiltration to the quarry cavern and thus change the groundwater levels. Such alternation in the groundwater hydrology will subsequently change the hydraulics and/or hydrology of the natural streams on the ground level and result in aquatic ecosystem degradation or loss, and reduced water discharge to the nearby reservoirs.

2. Although water drawdown in reservoirs or watercourses near or above the proposed underground quarry extent may occur with insignificant level according to PP, such environmental impacts can be catastrophic and hard to be accurately predicted and mitigated. On the other hand, several species of concern have been recorded in the concerned watercourses in PP. Therefore, a contingency plan should be formulated to cope with any abnormality in the nearby streams and reservoirs caused by the Project. Moreover, diversion of watercourses should be avoided as far as practicable.

3. Aboveground project footprint, including stockpiling site and worker station etc., should not go beyond the designated boundary of the aboveground works area (i.e. zero footprints in “Conservation Area” of OZP and aboveground of Tai Lam Country Park).

4. Construction and demolition (C&D) materials, chemical wastes, refuse etc. should be properly stored, transported, and finally disposed of at the designated facilities and/or environmentally treated. Unauthorized disposal of solid waste should be strictly prohibited. Deterrent clauses should be incorporated in the work contracts to monitor and penalize any fly-tipping activities.

5. Also, the dump trucks should be prohibited to access to sensitive areas such water gathering grounds, “Conservation Area” and country parks to avoid fly-tipping and disturbance to habitats and streams/watercourses. The project proponent could consider applying real-time GPS tracking technology to trace the tracks of the dump trucks and installing 24-hour surveillance video cameras at the roads (e.g. Chui Fuk Road, Fuk Hang Tsuen Path, Shui Fu Road, etc.) leading to the sensitive areas to monitor any irregular activities of the dump trucks.

6. Since the cavern is located in granite bedrock, there is a potential health risk of radioactive radon gas emission. Although a health risk assessment of radon gas emission is not required by the EIA Ordinance, the project proponent should still consider the mitigation measures of such issue as the previous EIA for the Sha Tin Cavern Sewage Development Work did (AEIAR-202/2016). Sufficient ventilation and filtration systems should be installed in the project site to control the radon level not exceeding the latest EPD’s Indoor Air Quality Objectives.

7. 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.

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).