Policy Comments & Advocacy

Green Power would like to draw your kind attention to our concerns regarding the Project Profile (PP) for direct application for an Environmental Permit (DIR) for the proposed Marina Development at the Expansion Area of Aberdeen Typhoon Shelter (this Project). This Project proposes to establish a marina accommodating up to 200 berthing spaces for pleasure vessels up to 50m in length, covering approximately 9.9 ha of designated berthing area at Tai Shue Wan, 1.1 ha of designated water space north of the existing eastern breakwater, 1.25 ha of total floating area, and 0.6 ha of landside marina facilities at Po Chong Wan Temporary Industrial Area including a marina clubhouse, boat repair and maintenance workshop, and dry berth. While the Project Proponent intends to seek permission to apply directly for an Environmental Permit (EP) under Sections 5(1)(b) and 5(11) of the Environmental Impact Assessment Ordinance (EIAO), we consider that several well-recognized potential environmental and ecological impacts associated with the marina construction and operation have not been fully addressed or mitigated in PP.

Key Concerns

1. Green Power is particularly concerned about several key issues related to this Project:

• This Project must not impose adverse impacts on the ecology, water quality, hydrodynamics, and sensitive environment of Tai Shue Wan, Aberdeen Channel, and adjacent marine waters.  

• This Project should not trigger any environmental or ecological vandalism along the Southern District coastline, marine habitats, and adjacent natural shores.

• Comprehensive site-specific assessments and stringent mitigation measures must be enforced for both construction and operational phases.

Water Quality, Hydrodynamics, and Odour Prevention

2. Antifouling Agents and Ecotoxicity: During the operational phase, the berthing of up to 200 pleasure vessels will introduce antifouling agents and paints that gradually leach or flake off into the water column. These chemicals are toxic at low concentrations to marine organisms and local coral communities. In view of the large fleet of vessels berthed at the Project site, a comprehensive ecotoxicity assessment should be conducted to evaluate the cumulative impact of leached antifouling agents on marine wildlife, and measures must be established to protect recreational water users.

3. Hydrodynamic Alteration and Risk of Anoxia/Odour: The installation of 1.25 ha of floating pontoons, marine piles, landside connecting ramps, and berthing structures within the enclosed expansion area of Aberdeen Typhoon Shelter (ATS) will alter local hydrodynamics. Owing to reduced water flow and turn-over rates inside the typhoon shelter, hypoxic or anoxic conditions may occur in the water column and seabed sediment under favorable meteorological or stratified conditions.

4. Odour Nuisance Prevention: Decomposition of organic pollutants under anoxic conditions could generate unpleasant smelly gases (e.g., hydrogen sulphide). This will spoil aesthetic functions and cause severe odour nuisance to marina users, vessel crews, and neighbouring sensitive receivers, including the Fullerton Ocean Park Hotel (ASR10a/10b) and nearby public open spaces. Water flow and turnover rates must be thoroughly modeled across all water depth layers to ensure structural layouts do not create stagnant traps for smelly gas formation.

5. Construction Site Effluent Control: During construction phase, any surface runoff, site sewage, chemical waste, or effluent discharge into the marine environment must be strictly prohibited. Effective measures such as silt curtains and perimeter channels must be fully deployed to intercept pollutants and refrain suspended solids from dispersing toward identified coral colonies at Tai Shue Wan and south of Tai Shue Wan.

6. Spillage Response Plan: An Accidental Spillage Prevention and Response Plan should be prepared, submitted, and approved prior to the issuance of the EP to handle accidental fuel or chemical spillages from marine vessels and maintenance facilities.

Protection of Marine Ecology, Eco-features, and Bird Safety

7. Coral Protection: Previous marine surveys identified hard coral species of conservation importance within and adjacent to the Project site, including Bernardpora stutchburyi, Oulastrea crispata, and Tubastraea sp.. Direct physical disturbance, excessive sedimentation, or shading impacts on these coral colonies during marine piling and precast connection works must be strictly avoided.

8. Verification of Eco-features: If eco-features or eco-shoreline designs (e.g., eco-pontoons or textured structural surfaces) are proposed on marine piles or landside connections to create habitats for intertidal and subtidal epifauna, the Proponent should submit concrete evidence, exact horizontal/vertical extents, and reference natural intact shoreline habitats to justify their ecological feasibility. These features must be monitored through subsequent Environmental Monitoring and Audit (EM&A) programmes.

9. Work Boundary Confinement: All construction activities, material storage, machine parking, and vessel berthing must be strictly confined within the Project works boundary. No works activities or equipment staging should trespass onto natural rocky shores, natural shorelines, or geomorphological features outside the site boundary.

10. Bird Collision Mitigation: The proposed landside marina clubhouse and administrative buildings should adopt bird-friendly architectural designs. The use of large-sized reflective glass walls should be avoided, or proper preventive measures—such as non-reflective glass, visual patterns/stickers, bird deterrent devices, or screens—must be incorporated.

Waste Disposal and Prevention of Eco-Vandalism

11. C&D Waste and Sediment Management: Construction activities involving marine piling and precast deck placement will generate C&D materials, chemical wastes, and disturbed sediments. To prevent fly-tipping and illegal dumping on land or at sea, real-time GPS tracking systems must be mandatorily fitted onto all land dump trucks and marine work vessels/barges.

12. "No-Go" Zone Alarm Systems: Ecologically sensitive marine and coastal zones should be designated as "no-go" areas, linked to an instantaneous alarm system that triggers immediate alerts if dump trucks or work barges encroach upon these zones.

13. Contractual Enforcement: Stringent deterrent clauses, strict documentation, verification, and penalty mechanisms should be incorporated into works contracts to enforce compliance.

14. Stockpile Protection: C&D waste, loose materials, and chemical containers stored on land or barges must be securely covered and kept away from rainfall or runoff to avoid washdown into Aberdeen Channel during rainstorms.

Air Quality, Fixed Noise, and Workshop Operations

15. Landside Maintenance Workshop Controls: This Project includes landside facilities at Po Chong Wan Temporary Industrial Area comprising a boat repair and maintenance workshop, dry berth, and E&M facilities. Potential air emissions (volatile organic compounds from vessel painting/maintenance) and fixed noise from workshop operations must be mitigated through local exhaust ventilation, acoustic enclosures, and adequate buffer distances.

16. On-Shore Power Supply (Cold Ironing): On-shore power systems should be provided at all berthing pontoons and made mandatory for berthed pleasure vessels to connect to the local electrical grid, completely eliminating hoteling emissions from auxiliary engines.

17. Vessel Fuel Compliance: All marine construction vessels and operational shuttle boats must strictly comply with the Air Pollution Control (Fuel for Vessels) Regulation and Air Pollution Control (Marine Light Diesel) Regulation to minimize NOx, SO2, and particulate emissions.

Climate Resilience

18. As major structures of this Project—including floating pontoons, pile guide structures, gangways, and landside landings—are situated in coastal waterbodies, the design must fully address extreme weather risks associated with climate change, including super typhoons, heavy rainstorms, storm surges, and sea level rise.

19. Structural safety, anchorage integrity, and emergency response procedures under severe typhoon scenarios must be rigorously evaluated to prevent dislodgement of pontoons or breakaways of berthed vessels.

Conclusion

In conclusion, Green Power considers that this Project constitutes a material change to the original project, i.e. Expansion of Aberdeen Typhoon Shelter (EIA-267/2025). This PP for Direct Application for Environmental Permit (DIR) has not provided sufficient site-specific data or conducted comprehensive ecotoxicity, hydrodynamic, and operational workshop assessments tailored to this 200-berth marina development. Granting an EP directly without requiring a detailed EIA report risks overlooking critical water quality, ecological, and operational impacts on Aberdeen Channel and Tai Shue Wan. We strongly urge EPD to require a full EIA study under the EIAO or impose strict, legally binding conditions in the EP to safeguard the marine ecology and environmental quality of the Southern District based on approved EIA Report of Expansion of Aberdeen Typhoon Shelter (AEIAR-267/2025) and conditions stipulated in corresponding EP (EP-660/2025 and EP-660/2025/A). Circumvention of approval conditions stated in AEIAR-267/2025, EP-660/2025 and EP-660/2025A is unacceptable without justification in environmental and legal context.

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).