Dr. CHUI Ho Kwong, Samuel, JP
Director of Environmental Protection
EIA Ordinance Register Office
Environmental Protection Department
(E-mail: eiaocomment@epd.gov.hk)
Green Power would like to draw your kind attention to our views and comments about the above-captioned EIA Report.
1. The watershed of Ngau Tam Mei will discharge the runoff to Ngau Tam Mei Channel which feeds Mai Po Inner Deep Bay Ramsar Site. Any surface runoff generated from the Project site during both construction and operation phase should be prevented from discharging into neighbouring river channels, stormwater drainage, fishponds and wetlands directly. We proposed that related preventive and mitigation measures should be incorporated into the specifications of the works contract.
2. Sewage and wastewater generated should be fully collected and carried away from the Project site. Sediments, soil, excavated materials should not be stockpiled near to the streams or water channels to avoid washing down to water bodies during rainstorms. Any bare soil surfaces and temporarily stored loose materials should be covered and checked especially when rainstorms are anticipated, and kept away from rainfall or runoff.
3. Most of the areas adjoining the project site are countryside places and fishponds, any fly-tipping of solid wastes generated from this project will be hard to combat. Even if such incidents are spotted, reinstatement can seldom be implemented because of various reasons such as land ownership, landuse zoning and etc. Therefore, generation, transportation and disposal of solid wastes should be under stricter control. Although it is mentioned in Section 6.3.3.6 that a GPS or equivalent system will be implemented to monitor dump trucks, it is recommended to include areas such as countryside places, fish ponds and agricultural lands as “no-go” areas to protect those sensitive habitats. An instantaneous alarm system should be utilised that dump trucks will trigger the alarm system when they encroach these no-go areas.
4. Ngau Tam Mei Water Treatment Works (NTM WTW) and Ngau Tam Mei Fresh Water Primary Service Reservoir (NTM FWPSR) are both situated on the northern slope of Kai Kung Leng where the vegetation is more flourish than those on the southern slope due to less disturbance by hillfires. Site regulations for hillfire prevention should be clearly stipulated in the specifications of the works contract, including no open burning of domestic, C&D and yard wastes, no smoking, no food cooking, etc. in Project sites and country park areas. Portable firefighting equipment should be installed in the Project sites, especially in vicinity of vegetated areas.
5. As some precious plants such as Incense Tree (Aquilaria sinensis) were recorded, the locations of these plants should not be exposed to minimize the risk of illegal plant collection. The temporary access paths and working places should be away from the locations of precious plants as far as possible.
6. The vegetation and trees should be properly protected from any damages brought about by the proposed project against machineries, earth works, vehicles, piling of materials, etc. Damages to roots, trunks and branches of trees should be avoided by proper positioning and alignment of proposed structures and fresh water trunk mains, and observing strictly the relevant guidelines for trees protection. Tree pruning works should be kept minimal and conducted under the supervision of certified arborist.
7. Native species are preferred for the compensatory trees in view of the proximity of country park and “Conservation Area” to the Project sites. No invasive species, such as Leucaena leucocephala, should be re-planted.
8. According to Section 8.2.4.14 & Section 8.2.4.17, breeding behaviours of avifauna species and breeding activities of herpetofauna species were recorded during the surveys. However, the breeding information was not presented in the report. If there were breeding behaviours or activities, the locations should be protected from any works during the breeding periods of those species.
9. Safety design and measures should be in place to deal with any accumulation/evolving of hazardous gas, especially in enclosed spaces in the site, and leakage to the engulfed valley of Ngau Tam Mei during both construction and operational phase.
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,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power
Yours faithfully,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power