Policy Comments & Advocacy

Green Power would like to draw your kind attention to our concerns and suggestions regarding the above-captioned Project Profile (PP) submitted for direct application for an Environmental Permit under Section 5(11) of the Environmental Impact Assessment Ordinance (EIAO).

Since the project site is situated entirely within the boundary of Tung Chung Fort, a Declared Monument under the Antiquities and Monuments Ordinance (Cap. 53), and is immediate adjacent to highly sensitive village areas (Sheung Ling Pei and Ha Ling Pei) and Conservation Areas (CA) (a fung shui wood), stringent pollution control and waste monitoring mechanisms must be implemented to prevent any irreparable environmental or cultural damage during the construction phase.

We would like to raise the following comments and requirements, with particular focus on waste management:

Asbestos-Containing Material (ACM) Control

1. The PP indicates that repair works to the existing hall roof will dismantle and generate approximately 0.07 m3 of Asbestos-Containing Material (ACM). To thoroughly eliminate potential airborne asbestos hazards, a registered asbestos consultant must be commissioned to execute a comprehensive Asbestos Investigation Report (AIR) and an Asbestos Abatement Plan (AAP) for EPD's explicit approval before any physical intervention. All ACM removal works must be conducted by a registered asbestos contractor. No air-borne asbestos fibre should be leaked to ambient air.

Secure Storage and Disposal of Asbestos Waste

2. Given that secure landfill burial (at WENT Landfill) is the only proven method for ACM disposal in Hong Kong, all collected asbestos waste must be handled and transported by a licensed chemical waste collector following statutory requirements to avoid any localized stockpiling or accidental rupture near the surrounding village residential receivers (ASR1 to ASR3) or the adjacent tourist-accessible information centre.

Enforcement of Waste Tracking via Real-Time GPS

3. To counter illegal dumping and fly-tipping (especially of ACM-contaminated wastes) within the ecological framework of Tung Chung and South Lantau, a strict trip-ticket system must be established in compliance with DEVB TC(W) No. 6/2010. Crucially, all dump trucks deployed for removing both inert C&D materials (estimated 9.38 m3) and non-inert C&D materials (estimated 0.02 m3) must be mandatorily equipped with operational real-time GPS tracking devices. It is recommended to include areas mentioned in paragraph 4 as "no-go" areas to protect those sensitive habitats. An instantaneous alarm system should be utilised that dump trucks or waste-loaded vehicles will trigger the alarm system when they encroach these no-go areas. These spatial tracking data should be regularly audited by the Independent Environmental Checker (IEC).

4. In order to protect the ecosystem and natural environment of Tung Chung River Valley cum Bay and South Lantau from air pollution and illegal dumping, large vehicles, construction / dump trucks and similar machineries associated with the Project must be prohibited from entering the section of Tung Chung Road between Ha Ling Pei and Shek Mun Kap, and all sections of South Lantau Road, as well as Chung Mun Road and section of Yu Tung Road to the west of Chung Yan Road. Vehicles that have justified reasons for entering need to seek formal approval from relevant authorities and be closely monitored with GPS devices.

Deterrent Clauses and CCTV Surveillance for Waste Management

5. Formally legally binding deterrent clauses must be incorporated directly into the contractor’s works contracts to monitor, penalize, and rectify any fly-tipping activities. A high-resolution closed-circuit television (CCTV) surveillance system must be set up at the designated material storage areas and the vehicular/material access gate near the playground. The CCTV recordings must be retained for compliance verification and inspection by the relevant authorities.

Chemical Waste Handling and Spill Prevention

6. The general chemical waste produced from entire building repair activities (e.g., waste termiticides and hazardous paint detergents) must be securely stored inside specialized chemical storage containers within a bunded, impermeable temporary storage zone. Appropriate labels matching Schedule 2 of Cap. 354C must be visibly affixed. A licensed chemical waste collector must be appointed to safely clear the materials on a standard periodic schedule for treatment at the Chemical Waste Treatment Centre (CWTC) in Tsing Yi.

Site Surface Runoff and Water Pollution

7. To prevent any point-source and non-point-source washouts from entering the nearby Wong Lung Hang Channel (WSR1, located 109 meters away) or the public storm drains, the contractor must closely implement sand and silt removal facilities in strict accordance with ProPECC PN 2/24 "Construction Site Drainage". All site runoff from washing or wet works must pass through sand traps and filtration units to satisfy the explicit discharge standards of the Water Pollution Control Ordinance (WPCO) license before releasing. No construction materials or general refuse should be placed in positions prone to storm washout.

8. Polluted runoff from the Project site will contain asbestos, paint and chemicals that must not be allowed to be discharged out of the Project site or to stormwater drainage. Measures for avoidance of generation and treatment of polluted runoff must be drawn and approved by relevant authority in prior to commencement of works.

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).