Policy Comments & Advocacy

Green Power would like to draw your kind attention to our concerns and recommendations regarding the Project Profile (PP) for the Proposed Residential Development in "Residential (Group C)1" Zone at Various Lots in D.D. 104 & Adjacent G.L. at Kam Pok Road in Yuen Long, N.T. (the Project). Several critical environmental issues that need to be addressed in the upcoming EIA study are highlighted.

Ecological Impacts

1. The proposed development site is situated within Deep Bay Buffer Zone 2 and in close proximity to ecologically sensitive areas, including the Planned Sam Po Shue Wetland Conservation Park (approx. 90m to the north), the Deep Bay Wetland Outside Ramsar Site Priority Site, and Conservation Areas (CA). Although the site is currently largely covered by grassland with some plantation and reed, it forms part of the wider Deep Bay wetland ecosystem that supports waterbirds and wildlife.

2. Comprehensive year-round ecological surveys must be conducted to establish robust baseline data covering all seasons, particularly to account for seasonal fluctuations in waterbirds and migratory species utilizing the Ngau Tam Mei Channel (NTMC) and adjacent wetland habitats. Surveys must also specifically target species of conservation importance, such as the Eurasian Otter (Lutra lutra) and amphibians/reptiles known to inhabit or transit the Deep Bay Area.

3. The EIA study must rigorously evaluate potential indirect disturbances to NTMC and local waterbird flight lines during both construction and operational phases. Adequate mitigation measures—such as building setbacks from NTMC, effective buffer planting, and restrictions on intrusive lighting and noise—must be incorporated into the project design to prevent habitat degradation and wildlife disturbance.

Water Quality and Hydrological Impact

4. The Project interfaces with existing nullahs, drainage channels (including NTMC), and stormwater systems within the Deep Bay catchment. Construction activities such as site formation, excavation, and foundation works will pose significant risks of silty runoff and pollutant discharge. "Zero discharge" policy to Deep Bay for untreated stormwater and sewage during both construction and operation phases should be strictly observed.

5. During the construction phase, comprehensive site drainage plans following EPD’s ProPECC PN 2/24 must be strictly enforced, incorporating adequately designed sand and silt removal facilities, regular maintenance, and rigorous control over accidental chemical or fuel spills. For the operational phase, proper connection to planned public sewers leading to the Nam Sang Wai Sewage Pumping Station (SPS) must be fully secured before any population intake. Furthermore, the on-site SPS must be engineered with robust odour control (e.g. enclosed structures, deodorizers) and emergency response plans to prevent any sewage overflow into adjacent watercourses.

Design, Landscape and Visual Mitigation

6. The Project introduces medium-density residential blocks, clubhouses, a kindergarten, retail facilities, and a proposed landscape pond. The EIA study must thoroughly assess landscape and visual impacts, particularly on key public viewing points along Yau Pok Road, Kam Pok Road, and surrounding hillslopes. Comprehensive tree surveys across the entire expanded project boundary must be conducted to identify and preserve existing landscape resources and mature trees wherever feasible.

7. Building dispositions, heights, and architectural designs should be carefully optimized through responsive site planning, minimizing visual intrusion and maintaining natural mountain backdrops. The proposed landscape pond should be integrated with genuine ecological functionality, enhancing local biodiversity and visual amenity.

Waste Management and Fly-Tipping Prevention

8. Given the rural and transitional nature of the Kam Pok Road area, construction and demolition (C&D) waste management requires stringent oversight to prevent illegal dumping and fly-tipping. We propose to include in the Environmental Permit the mandatory implementation of a trip-ticket system coupled with GPS tracking for all dump trucks transporting construction waste and excavated materials. During operation, municipal solid waste and chemical waste from facilities and the on-site SPS must be handled and collected regularly by licensed contractors in accordance with statutory regulations.

Cumulative Impacts and Public Consultation

9. The Project interacts with numerous major concurrent developments in the vicinity, including the Site Formation and Infrastructure Works for Public Housing Development at Sha Po, the Northern Link (NOL) project, development at Ngau Tam Mei Area, and the Northern Metropolis Highway - San Tin Section. Cumulative ecological, water quality, noise, and air quality impacts must be thoroughly assessed in a holistic manner to prevent combined environmental overload in the Yuen Long district.

10. Finally, we urge the Project Proponent and relevant authorities to arrange transparent public consultations once detailed EIA findings and data become available, ensuring that community and conservation concerns are fully addressed.

Thank you for your attention to these matters. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).