Policy Comments & Advocacy

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

1. The Project site constitutes a rare and large open wetland with remarkable ecological functions within the Inner Deep Bay area. The records of various avifauna species of conservation importance (Section 3.2.1.9) in the West Ash Logoon indicate its high ecological values.

2. Even though “waterbirds are mobile and opportunistic in nature, and alternative habitats are available in the vicinity”, it is invalid to claim that the induced ecological impacts on the waterbirds are negligible (Section 4.2.5.4). The Project Site is possibly a regular (i.e. not in occasional) supporting habitat to the Inner Deep Bay area. Moreover, the size of the West Ash Logoon is outstanding from the so-called alternative habitats near the Project site, so it provides an unique and valuable habitat to waterbirds.

3. In addition, the breeding period of Little Grebe in Hong Kong ranges from January to November according to the Hong Kong Bird Watching Society.⁽¹⁾ However, the bird survey period (i.e. March to May) for this Project is insufficient to capture the latest status of Little Grebe at the Project site. A year-long bird survey scheme is needed to make an accurate ecological impact assessment.

4. In view of the above, the ecological impacts are underestimated or omitted in the PP. As an undesirable result, no mitigation measures are proposed in the PP to compensate for the permanent loss of the West Ash Logoon wetland. We posit that compensation of an open wetland is required to maintain the ecological carrying capacity of the whole Deep Bay ecosystem.

5. The Project site is located in the Deep Bay Water Control Zone. Therefore, the Zero Discharge Policy should be strictly observed for the discharge of wastewater.

6. In particular, surface runoff at the Project site should be properly collected and treated before discharge to the Deep Bay water body. The temporary drainage system should be well maintained and capable to cope with rainstorm conditions.

7. Construction and demolition (C&D) materials, chemical waste and general refuse generated by the Project should be properly stored, transported, and finally disposed of at the designated facilities and/or treated environmentally. We opine that the installation of a CCTV system at the vehicular entrance and exit of the Project site (Section 5.1.4.1) is insufficient to deter fly-tipping activities. A more proactive trip ticket or instant route tracking system should be considered to monitor the final dumping location.

8. Vegetation clearance should be kept minimal as far as possible, compensatory native tree planting should be conducted accordingly.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 39610 200, F: 2314 2661, Email: info@greenpower.org.hk).