EIA

Kowloon-Canton Railway Corporation (KCRC)
East Rail Extension - Hung Hom to Tsim Sha Tsui
Application for Approval of an EIA Report Submitted on 28 September 1999
(Application No. EIA - 032/1999)

Reasons for the EIA Report Submitted on 28 September 1999 Not Meeting the Requirements of the EIA Study Brief (the Study Brief) and Technical Memorandum on EIA (TM)

Based on the information in the EIA report submitted on 28 September 1999, serious construction noise exceedences up to 7-22 dB(A) at various locations affecting many people and of considerable durations up to 11-20 months, have been identified, even after the incorporation of mitigation measures stated in the EIA report. This will have very severe adverse environmental effects on the community. The major exceedences come from the "cut and cover" construction method for the pedestrian subway at Mody Road. Despite the magnitude and duration of the adverse construction noise impacts and the number of people being affected, the EIA report submitted on 28.9.1999 has not thoroughly assessed, and presented with adequate justifications, the feasibility of alternative quieter construction methods such as bore tunnelling and deeper vertical alignment for the walkway or any other alternative measures. The EIA report has not exhausted and identified noise mitigation measures to reduce the magnitude and duration of the adverse construction noise impacts. Notwithstanding the seriousness of the residual construction noise impact, the EIA report submitted on 28 September 1999 has not described adequately and clearly the environmental comparisons of alternative construction methods or measures. In addition, although the EIA report indicates that noise insulation would be considered as the "last resort" upon the exhaustion of direct mitigation measures, no confirmation from the KCRC has been clearly stated in the report. S.1.4, S. 2.1 & S.3.7.1 of the Study Brief , S.4.4.2 of the TM, and Annexes 5 and 20 of the TM, have not been met.
The EIA report submitted on 28.9.1999 adopted an alignment and construction method that would require a substantial removal of the Signal Hill currently well vegetated. The proposed railway station would also impact on the Middle Road Children's Playground. These constitute the most crucial part of visual and landscape impacts of the whole project. There is insufficient information in the EIA report submitted on 28.9.1999, in the form of sections, plans and photomontages from key groups of visually sensitive receivers, to demonstrate the adequacy and effectiveness of the proposed mitigation measures to mitigate the landscape and visual impacts arising from the construction in Signal Hill, Middle Road Children's Playground and from the proposed railway station. This does not meet S.1.4, S.2.1, S.3.12.2, S.3.12.3 & S.3.12.6 of the Study Brief, Annex 20 of the TM, and S.6, 7 & 9 of Annex 18 of the TM.
According to Appendix K of the EIA report submitted on 28.9.1999, over 200 trees would be felled. The EIA report has not adequately described their conservation value nor sufficiently clear plans for compensatory planting to demonstrate that adequate mitigation measures have been recommended. This does not meet S.1.4, S.2.1, & S.3.12.5 of the Study Brief, and S.8.3 & S.8.4 of Annex 18 of the TM.
There is an open track of about 40m long next to the station that will have potential to cause operational noise impact. The assessment methodology shown is not acceptable. This does not meet S.3.7.1 of the Study Brief and Annex 13 of the TM.
The EIA report submitted on 28.9.1999 included three different options for spoil disposal, but has not clearly described their environment feasibility and what options and mitigation measures would be implemented under what circumstances. The EIA report should compare the benefits and disbenefits of these options and recommend, with substantiation, an environmentally acceptable disposal option for excavated material that is practicable and without unacceptable side effects. This does not meet S.3.10.1(ii) of the Study Brief and S.3.1 & 3.2 of Annex 15 of the TM.
Apart from the above, there are other omissions or deficiencies in the EIA Report submitted on 28 September 1999, as described below.

(a)	Minimum Cutting of Signal Hill for Maximum Preservation of Mature Trees
(i)	All the trees at the southern side of the Signal Hill will be disturbed by the proposed cut-and-cover construction method, and the public have already raised grave concern and objections to fell those trees. However, the EIA has not considered alternative designs to avoid the impact. S.4.4.2 of the TM has not been met.
(ii)	Paragraph 5.7 of the Executive Summary (ES) states that "engineering constraints presented show that cutting into Signal Hill is unavoidable". However, there is no justification showing what the engineering constraints are and why they are unavoidable. S.4.4.2 of the TM has not been met.
(b)	Outstanding Landscape & Visual Impact Assessments for the Proposed Railway Extension
(i)	Landscape impacts and associated mitigation works should cover both the construction stage and operational stage and should include Ho Man Tin traction substation. S.4.4.2 of the TM has not been met.
(ii)	Landscape and visual mitigation works at the operational phase have not been included in the Implementation Schedule. S.6.7 of Annex 20 of the TM has not been met.
(iii)	The visual impacts of the proposed conveyor and the marine working platform are severe, but if this option is still to be pursued, then relevant visual impact assessment has to be carried and described in the EIA report. S. 2.1, S.3.12.1 and S.3.12.6 of the Study Brief have not been met.
(iv)	The loss of urban amenities to include open space, mature street trees and amenity planting was not quantified in the EIA report submitted on 28.9.1999 to allow a proper assessment of the significance of landscape impacts. The EIA report has not included a section on the "Review of the Planning and Development Control framework" to allow an assessment of the compatibility of the proposed project with the surrounding area. This does not meet S.3.12.4 of the Study Brief and S.5 of Annex 18 of the TM.
(c)	Contradictions associated with the Temporary Offshore Marine Platform In accordance with paragraph 5.3 of the Executive Summary (ES), the EIA report states that no preferred option is recommended. However, this contradicts with paragraph 1.2 (iv) of the ES, stating that a temporary working platform is proposed to transport construction spoil. S.4.4.2 of the TM has not been met.
(d)	Inadequacy in the Construction Dust Impact Assessment
(i)	page 28, Table 4.5.1a "Emission Factors for Site Activities" The report should provide the detailed calculations in arriving at the emission factor (0.000011 g/s/m) for the paved road from the emission factor in USEPA's AP-42 for our comments. S.4.4.2 of the TM and S.5.14 of Annex 20 of the TM have not been met.
(ii)	page 66-67, Table 5.3.1b "Predicted Maximum 24 hr Ground Level TSP Levels" The cumulative dust concentrations due to background dust, dust from stone crusher, paved road and construction of Salisbury Road Underpass shown in second column of the table are checked from the modelling results in Appendix F. However, the results are higher than that determined by the report. For example, the highest concentration obtained by us is 95mg/m³ instead of 92mg/m³ stated in the report. The report should provide a sample calculation to show how the highest cumulative concentration shown in the second column of the table is obtained for our reference. S.4.4.2 of the TM and S.5.13 of Annex 20 of the TM have not been met.
(iii)	pages 65 to 67, Tables 5.3.1a & 5.3.1b The report should clarify why the predicted dust concentrations at air sensitive receivers (ASRs) presented in Tables 5.3.1a & 5.3.1b do not include some ASRs (for example, A1, A2, A3, A24, A25) indicated in Fig. 5.3.1. S.4.4.2 of the TM and S.5.14 of Annex 20 of the TM have not been met. The pollution contours for the predicted dust impact have not been included so that full picture of the predicted impact would be presented in the EIA report. S.4.4.2 of the TM and S.3.6 of Annex 12 of the TM have not been met.
(e)	Missing Information in Appendix J, Schedule of Mitigation Implementation As detailed in section 5.2.2.1 of the report, there are 10 work sites (including the site at Ho Man Tin) for this project. Obviously, not all the mitigation measures stated in Appendix J would be applicable to each work site. It is necessary to categorize each work site with individual implementation schedule. S.4.4.2 of the TM and S.6.7 of Annex 20 of the TM have not been met.
(f)	Blasting Works The EIA report should confirm the environmental acceptability, and the likely frequency and duration of the blasting works to be carried out. Section 4.4.2 and Annex 20 of the TM have not been met.
(g)	Other Outstanding Issues The electronic copy of the EIA report and the Executive Summary has not been submitted. S.6.3 and S.6.4 of the Study Brief have not been met.

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