Policy Comments & Advocacy

Green Power would like to draw your attention to our concerns for the above-captioned Environmental Impact Assessment (EIA) Report for the Hong Kong-Shenzhen Western Rail Link (Hung Shui Kiu to Qianhai) - Hong Kong Section (the Project).

Ecology

1. Although the egretries and ardeid night roosts around the Project site are located within the developed area surrounded by high-rise residential buildings and subject to frequent human activities, the tolerance and adaptability of ardeids in this area should not be overstated. Additional human activities, both qualitative and quantitative, should not be generated by the Project through locating relevant facilities (such as carparks, stockpiling, etc.) near to existing/new egretries and ardeid night roosts.

2. Given the substantial separation (i.e. more than 130 m) between the Project Area and the nearest egretries and roosting site, no direct adverse vibration impact arising from the construction activities is anticipated. However, noise, vibration, dust and night glare disturbance generated by travelling heavy vehicles, and associated facilities (such as carparks, stockpiling, etc.) should be avoided. Buffer zones during breeding season should be implemented to avoid these impacts. Number of ardeids nests and environmental impacts arising from the activities of the Project should be monitored.

3. Owing to local mortality case of Eurasian Otter suspectedly caused by dog attack was reported, keeping and feeding dogs in all construction sites, storage areas and other open areas utilized by the contractors under the Project should be prohibited as these dogs may potentially forage around Project area and attack wild animals. Abandoned and stray dogs remained after demolishment of brownfield and village houses should be properly captured and transferred away from the Project site.

4. Preventive measures must be implemented to avoid alternation/disturbance/damages/loss of coastal and intertidal habitats from discharge of wastewater/contaminated effluents, sediments/C&D waste, chemical wastes, refuse, reclamation, flytippings, etc.

Waste Management

5. Given the rural nature of the areas adjoining the Project site, fly-tipping of solid wastes generated from the Project must be strictly controlled. We reiterate the relevant recommendations in our previous submission regarding the Project Profile:

(a) Strict monitoring and control of the storage, transportation, and disposal of solid and C&D wastes.

(b) Incorporation of deterrent measures into the works contracts to prevent illegal dumping.

(c) Implementation of a comprehensive recycling plan to promote a zero-waste project.

(d) GPS tracking and instantaneous alarm systems for dump trucks entering restricted zones (e.g., Deep Bay Road, Kai Pak Ling Road, "Conservation Area" zones, "Coastal Protection Area" zones. "Green Belt" zones, wetlands and farmlands, etc.) to prevent fly-tipping and damage of wetlands and farmlands.

6. We stress that restricted zones should be delineated and instantaneous alarm systems to alert relevant personnel should be established throughout the construction phase regarding abnormal driving routes, stopover or trespassing on restricted zones by dump trucks.

Water Quality

7. The Project's alignment passes through areas connected to the Mai Po Inner Deep Bay Ramsar Site and in vicinity of oyster beds. To protect the ecology of the Ramsar Site and safeguard the production of oyster farms, preventive measures should be implemented.

8. To prevent untreated surface runoff and contaminated groundwater from discharging into Tin Shui Wai Nullah and Ha Tsuen Channel or their tributaries, or any drainage channels feeding to Deep Bay,

(a) Sufficient volume and treatment capacity of sand / silt removal facilities such as sand traps, silt traps and sedimentation basins should be provided to collect surface runoff collected from construction sites generated during heavy rainfall events.

(b) Perimeter channels at the boundary of the construction sites should be constructed to intercept storm run-off from flowing in so that it will not carry the dirt and pollutants and discharge to nearby inland drainage channels and minimize the volume of runoff required treatment.

(c) Sandbag or similar materials should be ready to construct temporary barriers whenever necessary during rainstorms.

(d) C&D waste and soil and chemical waste should not be stockpiled near any watercourses.

(e) Amount of contaminated surface runoff and groundwater should be predicted for worst case scenario so that the treatment and storage capacity of relevant facilities can be adequately installed.

9. To avoid any loss and disturbance to oyster farm operation and coastal habitats,

(a) Any geological and arbitrary weak zones/points should be identified before TBM tunneling works to prevent slurry loss or blowout to surface habitats such as fishponds, wetlands, intertidal mudflats, mangroves, oyster cultivation areas, etc.

(b) C&D waste and soil and chemical waste should not be stockpiled near seashores, especially proximity to sensitive habitats and oyster farms.

(c) Contingency plan to minimize impacts on oyster farms for any incidents should be devised.

(d) Sediment/pollutant plume modeling of dispersion of pollutants/suspended solid for any potential accidental discharge should be performed.

Climate Resilience

10. Flood risks induced by surface runoff at at-grade Ha Tsuen Depot should be properly addressed during the environmental assessment of water pollution with the consideration of exacerbating extreme climate events (e.g. torrential rainstorms, storm surges), and drainage impacts of neighbouring planned developments.

11. On the other hand, the Ha Tsuen Depot should not impose flood risk to its neighbouring areas with alternation of surface runoff or through stormwater discharge and any related proposed mitigation measures.

Cumulative Impacts

12. We stress the importance of including all potential environmental impacts of adjacent developments in the current EIA to avoid underestimation.

13. The project should not jeopardise the planning and establishment of Coastal Protection Park across Tsim Bei Tsui-Lau Fau Shan-Pak Nai coast.

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).