TABLE OF CONTENTS
3
Air Quality Impact.. 3-1
3.1 Introduction. 3-1
3.2 Environmental Legislation, Standards and Guidelines. 3-1
3.3 Description of Environment 3-3
3.4 Identification of Air Sensitive Receivers. 3-5
3.5 Identification of Environmental Impact 3-6
3.6 Assessment Methodology. 3-9
3.7 Prediction and Evaluation of Environmental Impacts. 3-19
3.8 Mitigation of Adverse Environmental Impacts. 3-22
3.9 Evaluation of Residual Impacts. 3-24
3.10 Environmental
Monitoring and Audit 3-24
3.11 Conclusion. 3-24
List of
tables
Table 3.1 Prevailing Hong Kong Air Quality Objectives. 3-1
Table 3.2 Proposed Hong Kong Air Quality Objectives. 3-2
Table 3.3
Average Concentrations of Pollutants in
the Recent Three Years (Year 2021 – 2023) at Southern EPD Air Quality
Monitoring Station. 3-4
Table 3.4 Background Air Pollutants in Year 2030 (Extracted from the PATH-v3.0) 3-4
Table 3.5 Representative Air Sensitive Receivers. 3-6
Table 3.6
Method Adopted in the Assessment for
the Identified Parking Sites, PTI, Bus and Shuttle Bus Terminus. 3-11
Table 3.7 Stability-dependent Multiplicative Factors. 3-19
Table 3.8
Predicted Cumulative Concentrations at
Representative Air Sensitive Receivers During the Operation Phase. 3-20
Table 3.9 Summary of Exceedance Zone Occurrences in the Contour Plots. 3-22
LIST OF FIGURES
|
Figure 3.1
|
Locations of Concerned PATH Grids
and Representative Air Sensitive Receivers
|
|
Figure
3.2
|
The Extent of Dredging
|
|
Figure
3.3a
|
Closest Separation Distances from
ASRs to Construction Vessels and Works Area During Peak Construction Period
|
|
Figure
3.3b
|
Closest Separation Distances from
ASRs to Construction Vessels and Works Area During the Minimum Vessel Utilisation Period
|
|
Figure
3.4
|
Emission Sources Within 500 m
Assessment Area
|
|
Figure
3.5a
|
Marine Emission Locations (Maneuvering) - Existing and Proposed Marine Routes
Entering/Leaving Aberdeen Typhoon Shelter
|
|
Figure
3.5b
|
Marine Emission Locations (Maneuvering) - Proposed Marine Route Adjacent to Ap Lei
Chau Praya Road Within Aberdeen Typhoon Shelter
|
|
Figure
3.5c
|
Marine Emission Locations (Maneuvering) - Proposed Marine Route Adjacent to Sham Wan
Road Within Aberdeen Typhoon Shelter
|
|
Figure
3.5d
|
Marine Emission Locations (Maneuvering) - Ferry Services at the Proposed Landing
Facility at Proposed Eastern Breakwater
|
|
Figure
3.5e
|
Marine Emission Locations –
Adventure Ship
|
|
Figure
3.5f
|
Locations of Hotelling Emissions
|
|
Figure
3.6
|
Contours of Cumulative 10th
Highest Daily Average RSP Concentration at 1.5mAG during Operation Phase
|
|
Figure
3.7
|
Contours of Cumulative Annual
Average RSP Concentration at 1.5mAG during Operation Phase
|
|
Figure
3.8
|
Contours of Cumulative 19th
Highest Daily Average FSP Concentration at 1.5mAG during Operation Phase
|
|
Figure
3.9
|
Contours of Cumulative Annual
Average FSP Concentration at 1.5mAG during Operation Phase
|
|
Figure
3.10
|
Contours of Cumulative 19th
Highest Hourly Average NO2 Concentration at 1.5mAG during
Operation Phase
|
|
Figure
3.11
|
Contours of Cumulative 10th
Highest Daily Average NO2 Concentration at 1.5mAG during Operation
Phase
|
|
Figure
3.12
|
Contours of Cumulative Annual
Average NO2 Concentration at 1.5mAG during Operation Phase
|
|
Figure
3.13
|
Contours of Cumulative 4th
Highest 10-mins Average SO2
Concentration at 1.5mAG during Operation Phase
|
|
Figure
3.14
|
Contours of Cumulative 4th
Highest Daily Average SO2 Concentration at 1.5mAG during Operation
Phase
|
|
Figure
3.15
|
Contours of Cumulative 10th
Highest Daily Average RSP Concentration at 5mAG during Operation Phase
|
|
Figure
3.16
|
Contours of Cumulative Annual
Average RSP Concentration at 5mAG during Operation Phase
|
|
Figure
3.17
|
Contours of Cumulative 19th
Highest Daily Average FSP Concentration at 5mAG during Operation Phase
|
|
Figure
3.18
|
Contours of Cumulative Annual Average
FSP Concentration at 5mAG during Operation Phase
|
|
Figure
3.19
|
Contours of Cumulative 19th
Highest Hourly Average NO2 Concentration at 5mAG during Operation
Phase
|
|
Figure
3.20
|
Contours of Cumulative 10th
Highest Daily Average NO2 Concentration at 5mAG during Operation
Phase
|
|
Figure
3.21
|
Contours of Cumulative Annual
Average NO2 Concentration at 5mAG during Operation Phase
|
|
Figure
3.22
|
Contours of Cumulative 4th
Highest 10-mins Average SO2
Concentration at 5mAG during Operation Phase
|
|
Figure
3.23
|
Contours of Cumulative 4th
Highest Daily Average SO2 Concentration at 5mAG during Operation
Phase
|
|
Figure
3.24
|
Contours of Cumulative 19th
Highest Hourly Average NO2 Concentration at 10mAG during Operation
Phase
|
|
Figure
3.25
|
Contours of Cumulative 10th
Highest Daily Average NO2 Concentration at 10mAG during Operation
Phase
|
|
Figure
3.26
|
Contours of Cumulative Annual
Average NO2 Concentration at 10mAG during Operation Phase
|
|
Figure
3.27
|
Contours of Cumulative 19th
Highest Hourly Average NO2 Concentration at 15mAG during Operation
Phase
|
|
Figure
3.28
|
Contours of Cumulative 10th
Highest Daily Average NO2 Concentration at 15mAG during Operation
Phase
|
|
Figure
3.29
|
Contours of Cumulative Annual
Average NO2 Concentration at 15mAG during Operation Phase
|
LIST OF
appendiCES
|
Appendix 3.1
|
Traffic Forecast for Air Quality
Assessment
|
|
Appendix 3.2
|
EMFAC-HK Model Assumptions
|
|
Appendix 3.3
|
Summary of Source Parameters for
Open Road Vehicular Emission Using AERMOD
|
|
Appendix 3.4
|
Detailed Calculation of Emissions
Associated with Bus and Minibus Termini, Heavy Goods Vehicle and Coach
Parking Sites
|
|
Appendix 3.5
|
Detailed Calculation of
Industrial Emissions
|
|
Appendix 3.6
|
Detailed Calculation of Marine
Emissions
|
|
Appendix 3.7
|
Determination of Surface
Characteristics Parameters for AERMET
|
|
Appendix 3.8
|
Derivation of Cumulative Annual
Average NOx to NO2 Conversion Equation using Jenkin Method
|
|
Appendix 3.9
|
Detailed Assessment Results under
With Project Scenario
|
3
Air Quality Impact
3.1
Introduction
3.1.1
This
section presents the assessment on potential air quality impacts on the air
sensitive receivers (ASRs) arising from construction and operation of the
Project. Assessment has been conducted in accordance with the criteria
and guidelines as stipulated in Annex 4 and Annex 12 of the Technical
Memorandum on Environmental Impact Assessment Process (EIAO-TM) as well as the
requirements given in Clause 3.4.3 of the EIA Study Brief (No.
ESB-357/2022).
3.1.2 The assessment has taken into consideration the latest project layout,
including the proposed breakwaters alignments with marine access in the form of
landing facilities, the proposed land access and the proposed wave wall in the
form of floating breakwater, as discussed in Section 2 and as shown in Figure 2.1.
3.2
Environmental
Legislation, Standards and Guidelines
3.2.1
The
criteria for evaluating air quality impacts and the guidelines for air quality
assessment are laid down in Annex 4 and Annex 12 of the EIAO-TM.
Air
Quality Objectives & Technical Memorandum on EIA Process
3.2.2 The Air Pollution Control Ordinance provides the statutory authority for
controlling air pollutants from a variety of sources. The Hong Kong Air
Quality Objectives (AQOs), which stipulate the maximum allowable concentrations
over specific periods for typical pollutants, should be met. The
prevailing AQOs are listed in Table
3.1. Subject to the effective date of the proposed AQOs
as shown in Table
3.2, the proposed AQOs are also considered as the
benchmark for conducting air quality impact assessment of this EIA study.
Table 3.1
Prevailing Hong Kong Air Quality Objectives
|
Pollutants
|
Averaging Time
|
Concentration Limit (µg/m3) [1]
|
Number of Exceedance Allowed per Year
|
|
Respirable Suspended
Particulates (RSP or PM10) [2]
|
24-hour
|
100
|
9
|
|
Annual [4]
|
50
|
N/A
|
|
Fine Suspended Particulates
(FSP or PM2.5) [3]
|
24-hour
|
50
|
18 [5]
|
|
Annual [4]
|
25
|
N/A
|
|
Nitrogen Dioxide (NO2)
|
1-hour
|
200
|
18
|
|
Annual [4]
|
40
|
N/A
|
|
Sulphur Dioxide (SO2)
|
10-min
|
500
|
3
|
|
24-hour
|
50
|
3
|
|
Carbon Monoxide (CO)
|
1-hour
|
30,000
|
0
|
|
8-hour
|
10,000
|
0
|
|
Ozone
|
8-hour
|
160
|
9
|
|
Lead (Pb)
|
Annual [4]
|
0.5
|
N/A
|
Notes:
[1] All measurements
of the concentration of gaseous air pollutants, i.e., sulphur dioxide, nitrogen
dioxide, ozone and carbon monoxide, are to be adjusted to a reference
temperature of 293 Kelvin and a reference pressure of 101.325 kilopascal.
[2] Suspended
particulates in air with a nominal aerodynamic diameter of 10µm or smaller.
[3] Suspended
particulates in air with a nominal aerodynamic diameter of 2.5µm or smaller.
[4] Arithmetic mean
[5] The
number of allowable exceedances of 18 days per calendar year as the benchmark
for conducting air quality impact assessment under Government Project
Environmental Impact Assessment studies.
Table 3.2
Proposed Hong Kong Air Quality Objectives
|
Pollutants
|
Averaging Time
|
Concentration Limit (µg/m3) [1]
|
Number of Exceedance Allowed per Year
|
|
Respirable Suspended
Particulates (RSP or PM10) [2]
|
24-hour
|
75
|
9
|
|
Annual [4]
|
30
|
N/A
|
|
Fine Suspended Particulates
(FSP or PM2.5) [3]
|
24-hour
|
37.5
|
18
|
|
Annual [4]
|
15
|
N/A
|
|
Nitrogen Dioxide (NO2)
|
1-hour
|
200
|
18
|
|
24-hour [5]
|
120
|
9
|
|
Annual [4]
|
40
|
N/A
|
|
Sulphur Dioxide (SO2)
|
10-min
|
500
|
3
|
|
24-hour
|
40
|
3
|
|
Carbon Monoxide (CO)
|
1-hour
|
30,000
|
0
|
|
8-hour
|
10,000
|
0
|
|
24-hour [5]
|
4,000
|
0
|
|
Ozone
|
8-hour
|
160
|
9
|
|
Peak Season [5]
|
100
|
N/A
|
|
Lead (Pb)
|
Annual [4]
|
0.5
|
N/A
|
Notes:
[1] All measurements
of the concentration of gaseous air pollutants, i.e., sulphur dioxide, nitrogen
dioxide, ozone and carbon monoxide, are to be adjusted to a reference
temperature of 293 Kelvin and a reference pressure of 101.325 kilopascal.
[2] Suspended
particulates in air with a nominal aerodynamic diameter of 10µm or smaller.
[3] Suspended
particulates in air with a nominal aerodynamic diameter of 2.5µm or smaller.
[4] Arithmetic mean
[5] 24-hour level
for NO2, peak season level for Ozone and 24-hour level for CO are
the new parameters in the World Health Organisation (WHO) Global Air Quality
Guidelines (AQGs) and AQO.
3.2.3 The Annex 4 of pre-amended EIAO-TM stipulated that hourly Total
Suspended Particulates (TSP) level should not exceed 500 µg/m3
measured at 298K and 101.325 kPa (one atmosphere) for construction dust
impact assessment.
Air
Pollution Control (Construction Dust) Regulation
3.2.4 The Air Pollution Control (Construction Dust) Regulation (Cap. 311R)
specifies processes that require special air quality control. Contractors
and site agents are required to inform Environmental Protection Department
(EPD) and adopt air quality control measures while carrying out “Notifiable
Works” (which requires prior notification by the regulation) and “Regulatory
Works”, to meet the requirements as defined under the regulation.
Air
Pollution Control (Non-road Mobile Machinery) (Emission) Regulation
3.2.5 The Air pollution Control (Non-road Mobile Machinery) (Emission)
Regulation comes into effect on 1 June 2015. Under the Regulation,
Non-Road mobile machinery (NRMMs), except those exempted, are required to
comply with the prescribed emission standards. From 1 September 2015, all
regulated machines sold or leased for use in Hong Kong must be approved or
exempted with a proper label in a prescribed format issued by EPD.
Starting from 1 December 2015, only approved or exempted NRMMs with a proper
label are allowed to be used in specified activities and locations including
construction sites. The Contractor is required to ensure the adopted
machines or non-road vehicle under the Project could meet the prescribed
emission standards and requirement.
Air
Pollution Control (Fuel Restriction) Regulation
3.2.6 The Air Pollution Control (Fuel Restriction) Regulation was enacted in
1990 to impose legal control on the type of fuels allowed for use and their
sulphur contents in commercial and industrial processes to reduce sulphur
dioxide (SO2) emissions. In June 2008 and April 2025, the Regulation
was amended to tighten the control requirements of liquid fuels.
Air Pollution Control (Marine Light Diesel)
Regulation
3.2.7 Since 1 April 2014, a statutory cap of 0.05% m/m on the sulphur content
of locally supplied marine light diesel has been imposed to reduce air
pollution from the marine sector under the Air Pollution Control (Marine Light
Diesel) Regulation.
3.3
Description
of Environment
3.3.1 The Project is located at Aberdeen Channel. The existing breakwaters
fall within an area shown as ‘Typhoon Shelter’ on the OZP. The land connecting
to the existing western breakwater is zoned “GB” and the land connecting to the
existing eastern breakwater is partly zoned “G/IC”, partly zoned “OU(Ocean
Park)” and partly shown as ‘Road’ on the OZP. The shoreline at Ap Lei Pai, Ap
Lei Chau and Tai Shue Wan are zoned “CPA” on the OZP.
3.3.2 The nearest EPD air quality monitoring station (AQMS) is Southern
monitoring station. As Southern monitoring station commissioned on 10
July 2020, the recent three years (2021 – 2023) averaged concentrations of air
pollutants relevant to the Project are recorded and summarised in Table 3.3. No exceedances of the 19th
highest hourly NO2 and annual NO2, the 4th
highest daily SO2, the 4th highest 10-minute SO2,
the 10th highest daily RSP and annual RSP, as well as the 19th
highest daily FSP and annual FSP were recorded at the Southern EPD AQMS during
the period of 2021-2023.
Table 3.3
Average Concentrations of Pollutants in the Recent Three Years (Year 2021 –
2023) at Southern EPD Air Quality Monitoring Station
|
Pollutant
|
Averaging Time
|
Prevailing AQOs
(µg/m3)
|
2021
|
2022
|
2023
|
|
SO2
|
10-min
|
4th Highest
|
500
|
36
|
40
|
31
|
|
24-hour
|
4th Highest
|
50
|
8
|
6
|
8
|
|
RSP
|
24-hr
|
10th Highest
|
100
|
53
|
48
|
53
|
|
Annual
|
50
|
26
|
24
|
25
|
|
FSP
|
24-hr
|
19th Highest
|
50
|
26
|
26
|
24
|
|
Annual
|
25
|
13
|
12
|
12
|
|
NO2
|
1-hr
|
19th Highest
|
200
|
123
|
105
|
114
|
|
Annual
|
40
|
30
|
25
|
26
|
|
CO
|
1-hr
|
Maximum
|
30,000
|
1,230
|
1,140
|
1,150
|
|
8-hr
|
Maximum
|
10,000
|
1,014
|
1,073
|
1,123
|
Notes:
[1]
All data is calculated from the hourly data provided in EPD’s website (http://epic.epd.gov.hk/EPICDI/air/station/?lang=en)
[2]
Reference conditions of gaseous pollutants concentration data: 293K and
101.325 kPa.
3.3.3 Apart from the air quality monitoring data, EPD has released a set of
background levels from “Pollutants in the Atmosphere and their Transport over
Hong Kong” (PATH) model (version 3.0). The PATH model is a regional air quality model developed by EPD
to simulate future background air quality concentrations in Hong Kong. At the
time of this assessment, PATH v3.0 is available in Smart Air Model Platform
(SAMP) v2.1 for Year 2026-2030, 2035 and 2040. Given the proposed Project
will be completed in Year 2030, the air quality predicted by PATH v3.0
for Year 2030 will be adopted. Year 2030 data of the assessment
area for NO2, RSP, FSP, and SO2 extracted from PATH v3.0
is presented in Table 3.4. The
predicted background concentrations of NO2, RSP, FSP and SO2
at various averaging times would be lower than the prevailing / proposed new
AQOs.
Table 3.4 Background Air
Pollutants in Year 2030 (Extracted from the PATH-v3.0)
|
Pollutant
|
Averaging Time
|
Prevailing AQOs (µg/m3)
|
Proposed AQOs
(µg/m3)
|
Concentration in PATH v3.0 (Year 2030)
|
|
(40,25)
|
(40,24)
|
(38,25)
|
(39,25)
|
(38,24)
|
|
SO2
|
10-mins
|
4th Highest
[1]
|
500
|
500
|
22
|
24
|
24
|
23
|
25
|
|
24-hour
|
4th Highest
|
50
|
40
|
6
|
6
|
6
|
6
|
7
|
|
RSP
|
24-hr
|
10th
Highest
|
100
|
75
|
49
|
49
|
50
|
49
|
50
|
|
Annual
|
50
|
30
|
18
|
18
|
19
|
18
|
18
|
|
FSP
|
24-hr
|
19th
Highest
|
50
|
37.5
|
28
|
28
|
29
|
28
|
28
|
|
Annual
|
25
|
15
|
11
|
11
|
11
|
11
|
11
|
|
NO2
|
1-hr
|
19th
Highest
|
200
|
200
|
65
|
71
|
81
|
71
|
85
|
|
24-hr
|
10th
Highest
|
-
|
120
|
27
|
30
|
34
|
30
|
41
|
|
Annual
|
40
|
40
|
12
|
13
|
16
|
13
|
17
|
|
Pollutant
|
Averaging Time
|
Prevailing AQOs
(µg/m3)
|
Proposed AQOs
(µg/m3)
|
Concentration in PATH v3.0 (Year 2030)
|
|
(39,24)
|
(39,23)
|
(38,23)
|
(40,23)
|
|
SO2
|
10-mins
|
4th Highest
[1]
|
500
|
500
|
25
|
27
|
28
|
25
|
|
24-hour
|
4th Highest
|
50
|
40
|
6
|
7
|
7
|
7
|
|
RSP
|
24-hr
|
10th
Highest
|
100
|
75
|
49
|
50
|
50
|
50
|
|
Annual
|
50
|
30
|
18
|
18
|
18
|
18
|
|
FSP
|
24-hr
|
19th
Highest
|
50
|
37.5
|
28
|
28
|
28
|
28
|
|
Annual
|
25
|
15
|
11
|
11
|
11
|
11
|
|
NO2
|
1-hr
|
19th
Highest
|
200
|
200
|
79
|
84
|
87
|
81
|
|
24-hr
|
10th Highest
|
-
|
120
|
35
|
39
|
44
|
35
|
|
Annual
|
40
|
40
|
14
|
16
|
19
|
15
|
Notes:
[1]
Values are given as highest 10-minute SO2 concentrations, which are
estimated based on EPD’s “Guidelines on the Estimation of 10-minute Average SO2
Concentration for Air Quality Assessment in Hong Kong”.
[2]
The 10th highest daily NO2 concentration is only included in the
proposed new AQO.
3.4
Identification
of Air Sensitive Receivers
3.4.1 In accordance with Annex 12 of the EIAO-TM, any domestic premises,
hotel, hostel, hospital, clinic, nursery, temporary housing accommodation,
school, educational institution, office, factory, shop, shopping centre, place
of public worship, library, court of law, sports stadium or performing arts
centre are considered as ASRs. Any other premises or place with which, in terms
of duration or number of people affected, has a similar sensitivity to the air
pollutants as the aforelisted premises and places is
also considered to be a sensitive receiver.
3.4.2 In accordance with the EIA Study Brief, the assessment area for air
quality impact assessment should be defined by a distance of 500 m away from
the boundary of the Project site. Illustration of the proposed assessment
area is presented in Figure 3.1.
3.4.3 For identification of the representative ASRs within the assessment area
that would likely be affected by the potential impacts from the construction
and operation of the Project, a review has been conducted based on relevant
available information including topographic maps, OZPs and other published
plans from Planning Department and Lands Department, along with any land use and development
applications approved by the Town Planning Broad, as
well as a site survey conducted on 7 August 2023 and 24 August 2024, in the
vicinity of the Project site. The representative ASRs within the assessment
area are presented in Table 3.5 and
illustrated in Figure 3.1.
Table 3.5 Representative
Air Sensitive Receivers
|
ID
|
Description
|
Land use
|
The Shortest Distance between
the ASR and the Project Boundary, m
|
Assessment Height
Above Ground (mAG) [1]
|
|
Existing ASRs
|
|
A1
|
Broadview Court Block 4
|
Residential
|
443
|
25 -140 [2]
|
|
A2
|
Larvotto
|
Residential
|
284
|
15-125 [3]
|
|
A3a
|
Shipyards
and workshops
|
Industrial
|
208
|
1.5-5
|
|
A3b
|
Shipyards
and workshops
|
Industrial
|
225
|
1.5-5
|
|
A4
|
Shipyard
and Temporary Industrial Area
|
Industrial
|
75
|
1.5-5
|
|
A5
|
Canadian
International School
|
Education
|
435
|
1.5-50
|
|
A6
|
Hong
Kong Juvenile Care Centre Chan Nam Cheong Memorial School
|
Education
|
403
|
1.5-30
|
|
A7
|
Victoria
Shanghai Academy
|
Education
|
324
|
5-55
[4]
|
|
A8
|
Water
World Ocean Park Hong Kong
|
Other
Specified Uses (Ocean Park)
|
84
|
1.5-10
|
|
A9
|
Ocean
Park Hong Kong
|
Other
Specified Uses (Ocean Park)
|
213
|
1.5
|
|
A10a
|
Fullerton
Ocean Park Hotel
|
Hotel
|
13
|
1.5-50
|
|
A10b
|
Fullerton
Ocean Park Hotel
|
Hotel
|
22
|
1.5-50
|
|
A11
|
Shipyard
and Temporary Industrial Area
|
Industrial
|
180
|
1.5-5
|
|
Planned
ASRs
|
|
PA01
|
The
Proposed Open Space at the Proposed Eastern Breakwater
|
Open
Space
|
Within
Project Boundary
|
1.5-5
|
|
PA02
|
The
Proposed Open Space at the Proposed Eastern Breakwater
|
Open
Space
|
Within
Project Boundary
|
1.5-5
|
|
PA03
|
The
Proposed Open Space at the Proposed Eastern Breakwater
|
Open
Space
|
Within
Project Boundary
|
1.5-5
|
Notes:
[1]
The lower bound of assessment height shown in the table is the lowest
level with air-sensitive uses, full range of assessment heights for each ASR
has been listed in the table.
[2]
ASR is located on podium. No air-sensitive uses below 25 mAG.
[3]
ASR is located on podium. No air-sensitive uses below 15 mAG.
[4]
Carpark is located at the ground floor. No air-sensitive uses below 5 mAG.
3.5
Identification
of Environmental Impact
Construction Phase
3.5.1
According
to the construction programme, the construction works of the Project is
tentatively scheduled to commence in 2026 and completed in 2030. Air quality
impact may arise from various construction activities of the Project, including:
· Construction of the proposed eastern
and western breakwaters which include dredging operations and other
construction works including Deep Cement Mixing (DCM) and rubble mound
filling. The dredging operations and other construction works will utilise
barges and will last for approximately 40 months;
· Construction of proposed land access
and proposed wave wall in the form of floating breakwater lasting for
approximately 12 months;
· Modification works of the existing
breakwaters lasting for approximately 12 months; and
· Material handling.
3.5.2
Based
on the preliminary construction programme and the estimated volume breakdown presented in Table
6.5 of Section 6, the
construction of the proposed breakwater includes a dredging operation lasting
approximately 9 months, with an estimated volume of approximately 241,263 m3
material to be dredged. The dredging locations are illustrated in Figure 3.2. As
illustrated in Figure 3.2,
the shortest separation distance between the dredging extent and the nearest
ASR is approximately 322 m. During the dredging operation, a maximum of 6
barges would be utilised. However, as advised by the Project Engineer the
project involves three work fronts, each work front utilising two barges - one
for transferring the dredged material and another stationed on-site to support
the dredging operations. Therefore, a maximum of 3 barges would be used per day
for the transfer of the dredged material, and there will not be overnight
storage of dredging material. The remaining 3 barges would be stationed on-site
to assist with the dredging works, and they will not store dredging material.
The dredged material would be placed on barges for transfer from the works area
for disposal. As dredging operations are marine-based activities, and the
moisture content of the dredged material is very high, fugitive dust emissions
are therefore expected to be minor during the construction period. The
potential odour impact from the dredging activities would be short-term as the
dredged material is transported away from the Project site once excavated and
is appropriately covered before transportation. Referring
to Section 6.4.31, the dredged material will be disposal to South Cheung
Chau and East of Ninepin, the potential transportation routing would be via East Lamma Channel, West Lamma Fairway and South Shek Kwu Chau Fairway (for South Cheung Chau) and via East Lamma Channel, south of Hong Kong Island and Tathong Channel (for East of Ninepin). The
navigation route of barges/construction vessels will be located away from any
ASR as far as practicable. With the implementation of mitigation
measures during the construction period to minimise the potential odour
mentioned in Section 3.8.2 and considering the large separation
distance between the dredging extent and the nearest ASR, adverse odour impact
from the dredged material is not expected.
3.5.3
Phasing
of construction works at multiple work fronts at different construction period
would be considered. Construction vessels would be
involved at each construction activities, such as construction of breakwater.
As outlined in Section 3.5.1, the dredging operation and other
construction works are expected to take approximately 40 months and would occur
in different construction periods. Two construction periods are highlighted:
one representing the peak construction period, which will utilise the highest
number of construction vessels, and the other representing the period with the
minimum number of construction vessels employed. The number of construction
vessels for other construction periods will be in-between the number of
construction vessels of the two highlighted construction periods. The peak construction period is anticipated to last
around 200 days, involving a maximum of 24 vessels per day, including 9
hopper barges, 10 dump lighters and 1 DCM barge (which are not propelled by an
engine) and 4 tugboats that facilitate the movement of the barges but will not
be stationed on-site, as illustrated in Figure 3.3a. the minimum vessel
utilisation period will last approximately 100 days, with a maximum of 9 vessels will operate daily. This includes 3 dump lighter barges, 3 hopper barges and 1 DCM barge,
which are not engine-propelled, along with 2 tugboats that assist in moving the
barges but will not be stationed on-site, as illustrated in Figure 3.3b. During the construction period, tugboats would not stay
at one works area but would be distributed across different works area of the
Project. In summary, the number of
construction vessels utilised during all the construction periods ranges from 9
to 24 vessels. As shown in Figure 3.3b, the shortest separation distance from
construction vessels to the nearest ASR (A10a) during the minimum vessel
utilisation period is approximately 109 m, and this case represents the
worst-case scenario, having the shortest distance to ASRs among all
construction periods. These
marine vessels would operate using fuel that complies with the Air Pollution
Control (Marine Light Diesel) Regulation, which requires that the sulphur
content of locally supplied marine light diesel (MLD) used in marine vessels
shall not exceed 0.05% by weight. Additionally, under the Air Pollution Control
(Fuel for Vessels) Regulation, vessels are prohibited from using any fuel other
than compliant fuel for combustion purposes while operating any specified
machinery in the waters of Hong Kong. These construction vessels would be
operated throughout the works area and would be stay away from any existing
ASRs as far as practicable. With the implementation of mitigation measures
listed in Section 3.8, adverse air quality impacts are not anticipated
from the construction vessels.
3.5.4
Fuel
combustion from the use of powered mechanical equipment (PME) during
construction works could be a source of PM, NO2, SO2 and
CO. As advised by Project Engineer, only
a small number of PMEs (approximately 4 PMEs) will be in operation at the same
time. Minor number of construction vehicles (i.e., approximately two
return trips of dump trucks per day) are anticipated during construction
phases. With the implementation of the requirements and measures stipulated in
the Air Pollution Control (Non-Road Mobile Machinery (NRMM)) (Emission)
Regulation and Air Pollution Control (Fuel Restriction) Regulation, the
emissions from construction equipment and dump trucks are not expected to cause
adverse air quality impact to the surrounding ASRs.
3.5.5 Based on the best available information at time of preparation of this
EIA, there is no concurrent project within the assessment area of the Project.
Operation
Phase
3.5.6
Potential
air quality impacts during the operation phase of the Project would be
associated with the following pollution sources located within the assessment
area:
· Background pollutant concentrations;
· Vehicular emissions from open
sections of existing and proposed roads within 500 metres from the Project boundary;
· Industrial emissions from Hospital
Authority Shum Wan Laundry (locations shown in Figure 3.4);
· Emissions associated with the coach parking, bus and minibus termini,
and shuttle bus terminus at Water World Ocean Park Hong Kong, shuttle bus
terminus at Fullerton Ocean Park Hotel, bus and minibus termini at Shum Wan
Road public transport interchange (PTI), and on-street heavy goods vehicle
(HGV) and non-franchised bus (NFB) parking at Ap Lei Chau Praya Road (locations shown in Figure 3.4); and
· Marine emissions from Aberdeen
Typhoon Shelter (ATS).
3.6
Assessment Methodology
Construction
Phase
3.6.1
Considering
the nature of the construction activities for the Project, the potential air
quality impact during the construction phase should be limited with the
implementation of mitigation measures stipulated in Air Pollution Control
(Construction Dust) Regulation and good site practices recommended in Section
3.8. Therefore, adverse construction air quality impact to
surrounding ASRs is not anticipated and qualitative assessment approach is
adopted for construction air quality impact assessment.
Operation
Phase
3.6.2 PATH and AERMOD models are used to simulate the dispersion of emission
from the sources identified in Section 3.5.6. The future background
concentrations for air pollutants from the PATH v3.0 model for the Year 2030,
available in the SAMP, are adopted. AERMOD model, the EPD approved air
dispersion model, is used to simulate vehicular emission associated with the
coach parking sites/termini (AREA, AREAPOLY and VOLUME sources), open road
emissions within the assessment area (LINE source), marine emission (POINT
source) and industrial emission (POINT source) within the assessment area.
Background
concentrations
3.6.3 As suggested by “Guidelines on Assessing the ‘TOTAL’ Air Quality
Impacts”, an integrated modelling system, PATH v3.0, which is developed and
maintained by EPD, is applied to estimate the background pollutant
concentrations. The PATH model simulates local emission sources such as open
road emission, marine emission, point sources, and aviation as well as regional
transport through meteorological processes at 1km x 1km resolution.
3.6.4 The assessment area covers 9 grid cells of PATH v3.0, namely grid
(38,23), (38,24), (38,25), (39,23), (39,24), (39,25), (40,23), (40,24) and
(40,25). The construction of the Project is tentatively scheduled in Year 2026
to 2030 and the Project will be commissioned in Year 2030. The PATH v3.0 for
the Year 2030 is adopted for estimating the background pollutant concentrations
during operation phase. The location of PATH v3.0 model grids are shown
in Figure 3.1.
Vehicular
emissions from open road
3.6.5 Ocean Drive, Shum Wan Road, Nam Long Shan Road and Ap Lei Chau Praya
Road would contribute to vehicular emissions within the assessment area. The
traffic data of the abovementioned roads, which is provided by traffic
consultant appointed under this study, including the projected 24-hour traffic
flows, vehicle compositions, and travelling speeds for operation phase are
adopted in this air quality assessment, and presented in Appendix 3.1. The traffic data was
submitted to Transport Department with no comment received, and the endorsement
is also supplemented in Appendix 3.1.
3.6.6 EMFAC-HK v4.3 model was adopted to estimate the vehicular emission rates
of NOx (i.e., initial NO + initial NO2), RSP and FSP for vehicular
emission arising from open road and PTI and shuttle bus terminus and on-street
parking within the assessment area. The “vehicle fleet” refers to all motor
vehicles operating on roads within this assessment area. The modelled fleet is
broken down into 18 vehicle classes based on the vehicle population provided by
EPD. The detailed input parameters and model assumptions made in EMFAC-HK model
are summarised in Appendix 3.2.
3.6.7 The vehicular emission burdens of NOx, RSP, and FSP from commencement
year to 15 years afterward, namely Years 2030, 2038 and 2045, were estimated by
using EMFAC-HK model and shown in Appendix
3.2. The vehicular emission attained the highest in Year 2030. Year
2030 was therefore selected as the representative assessment year for the
vehicular emission.
3.6.8 Open sections of all existing roads (e.g., Ocean Drive, Shum Wan Road, Nam
Long Shan Road and AP Lei Chau Praya Road) were included in this
assessment. An EPD recommended air dispersion
model, AERMOD, was used to assess the contribution due to vehicular
emissions (e.g., NO, NO2, RSP and FSP) from the open roads within
the assessment area.
3.6.9 The resulting hourly emissions of NO, NO2, RSP and FSP were
divided by the hourly traffic flow, the distance travelled to obtain the
emission factors in gram per km per vehicle. The calculated 24-hour
initial NO, initial NO2, RSP and FSP emission factors of 18 vehicle
classes for each road type were adopted in the subsequent air dispersion model,
AERMOD. The AERMOD vehicular input files are generated from SAMP v2.1 developed
by EPD. The scenario with zero-emission vehicles is considered in the composite
emission factors output by SAMP v2.1.
3.6.10 The methodology for configuring
AERMOD to assess vehicular emissions, including parameters such as source release heights, road width, and initial vertical dimension
coefficient, follows the guidelines outlined in the "Technical Note for
Modelling Vehicular Emission Using AERMOD" issued by EPD. The relevant
parameters utilised in this assessment are provided in Appendix 3.3.
Emissions associated with the coach
parking, bus and minibus termini, and shuttle bus terminus
3.6.11 According to the desktop study and site survey conducted
on 7 August 2023 and 24 August 2024, bus depots are not identified in
the assessment area. The locations, the distance from
Project boundary, and methods used to assess the start emissions from the
identified parking sites, PTI, bus and shuttle bus terminus, and coach bus parking site are detailed in Table 3.6.
These locations are also illustrated in Figure 3.4.
Table 3.6
Method Adopted in the Assessment for the Identified Parking Sites, PTI, Bus and
Shuttle Bus Terminus
|
ID
|
Name
|
Distance from Project
Boundary (m)
|
Approach for
Considering the Start Emission
|
|
E1
|
The Fullerton Ocean Park Hotel – Shuttle Bus
Terminus
|
25
|
Precise approach [1]
|
|
E2
|
Water World Ocean Park Hong Kong – Shuttle Bus
Terminus
|
16
|
Precise approach [1]
|
|
E3
|
Water World Ocean Park Hong Kong – Public Light
Bus Terminus
|
16
|
Broad-brush approach
|
|
E4
|
Water World Ocean Park Hong Kong – Franchised
Double Deck Bus Terminus
|
17
|
Broad-brush approach
|
|
E5
|
Water World Ocean Park Hong Kong – Coach
Parking Site
|
33
|
Precise approach [1]
|
|
E6
|
Shum Wan Road PTI
|
500
|
Precise approach [1]
|
|
E7
|
On-street HGV and NFB parking spaces at Ap Lei
Chau Praya Road
|
256
|
Precise approach [1]
|
Note:
[1] The detail of the precise approach is outlined in
the Technical Note on Calculation of Start Emissions in Air Quality Impact
Assessment published by EPD.
3.6.12 The
franchised bus and public light bus terminus of the Water World Ocean Park Hong
Kong (hereinafter referred to as “WWOP”) (E3 and E4) are small scale, with only
2 bus routes and 3 minibus routes. According to the bus schedules on
Citybus’ website, bus routes 629M and 629 (Central (Star Ferry) – Ocean Park
(Main Entrance/Water World)) are operated on specific days only. While bus
route 629 is only served once a day. Based on the public light bus schedules
provided by the service provider, there are a total of 9 headways for two
routes (29A and 29X) and total of 12 headways on Saturdays, Sundays and public
holidays for another minibus route (59S). Given that the limited number of
franchised bus and public light bus routes in the WWOP are provided, the start
emission in the WWOP (i.e., E3 and E4) are considered minor. Start emissions of
all vehicle types from these termini and all the roads leading to and leaving
from the bus and PLB termini is considered by broad-brush approach in which the
emission is allocated to the local roads.
3.6.13 The
start emissions, running exhaust emissions, and idling emissions (i.e., NO, NO2,
RSP, and FSP) associated with the shuttle bus termini at WWOP (E2) and
Fullerton Ocean Park Hotel (E1), coach bus parking site in the WWOP (E5),
Shum Wan Road PTI (E6) and on-street HGV and NFB at Ap Lei Chau Praya
Road (E7) are calculated based on the start emission and running exhaust
emission factors predicted by EMFAC-HK model, cold idling emission factors from
Calculation of Start Emissions in Air Quality Impact Assessment
published by EPD, warm idling emission factors from Road Tunnels: Vehicle
Emissions and Air Demand for Ventilation published by World Road Association
and traffic data including the idling time and no. of trips provided by the
traffic consultant based on at least 24 hour site survey on normal day and 1
public holiday day.
3.6.14 A
site survey conducted on 7 August 2023 and 24 August 2024 revealed that the
shuttle bus terminus at the Fullerton Ocean Park Hotel (E1) is semi-enclosed
without mechanical ventilation. In contrast, the shuttle bus terminus and coach
bus parking at the WWOP (E2 and E5), as well as the on-street HGV and NFB
parking spaces at Ap Lei Chau Praya road (E7), are open. On-site observations
indicated that there was no overnight parking of coaches at shuttle bus
termini. Additionally, the Shum Wan Road PTI (E6) is semi-enclosed and has been equipped with mechanical ventilation systems for exhaust. The emissions (i.e., start, running and idling emissions) associated
with E1, E2, E5, E6 and E7 were evaluated using the precise approach outlined
in the Technical Note on Calculation of Start Emissions in Air Quality
Impact Assessment published by EPD. For diesel vehicles equipped with
selective catalytic reduction (SCR) devices, start emissions were adjusted
based on the idling emission and would be released over total spread distance
of 700 m from where the start takes place, start
emissions for liquefied petroleum gas (LPG) minibus were adjusted based on the
idling emission and would be released over a total spread distance of 150 m
from where the start takes place, while running exhaust and idling
emissions would be released on the spot. At identified coach parking sites and
shuttle bus parking, running exhaust and idling emissions from
terminating and non-terminating vehicles, and adjusted start emission from
terminating vehicles are considered for emissions inside coach bus/shuttle bus
parking sites while the remaining adjusted start emission from terminating
vehicles is considered for emissions outside coach bus/shuttle bus parking
sites.
3.6.15 Since
the shuttle bus parking at Fullerton Ocean Park Hotel (E1) is semi-confined and
does not have any mechanical ventilation for exhaust, the starting emissions
are modelled as “AREAPOLY” sources, distributed at the side openings, ingress
and egress at E1. However, Shum Wan Road PTI (E6) is also semi-confined but is
equipped with the mechanical ventilation for exhaust, which is modelled as
“VOLUME” Sources in AERMOD. To avoid any underestimation, 100% of emission
within E6 is assigned to the openings, ingress and egress (“AREAPOLY” source)
and additional 100% of emission is distributed via the exhaust points (“VOLUME”
source). Emissions within open shuttle bus terminus (E2) and coach bus parking
sites at WWOP (E5), as well as the on-street parking sites at Ap Lei Chau Praya
Road (E7) are also modelled as “AREAPOLY” sources in AERMOD. Start emissions on
spread distance outside the identified parking sites/PTI/shuttle bus terminus
are modelled as “AREA” sources. The location of emission sources and the
detailed calculation of the emission are presented in Appendix 3.4. The meteorological
data and modelling parameters adopted in AERMOD are detailed in
Sections 3.6.30 to
3.6.31.
Industrial Emissions within the
Assessment Area and Major Point Sources within 4 km
3.6.16 According
to chimney survey conducted on 7 August 2023 and 24 August 2024, Hospital
Authority Shum Wan Laundry (HASWL) is identified as the only source of
industrial emissions within the assessment area, and the location is
illustrated in Figure 3.4. The chimney parameters such as
stack height, stack temperature, stack exit velocity, stack diameter, and
emission inventory of HASWL are referred to the approved EIA report on
Repositioning and Long-Term Operation Plan of Ocean Park (Register No.: AEIAR-101/2006) and the response
from the chimney owner/operator dated 16 June 2023 and the site surveys. The
correspondence from the chimney owner/operator is provided in Appendix 3.5. As a worst-case
scenario, it is assumed that these three chimneys operate 24 hours a day. The
emission sources are modelled as “POINT” sources in AERMOD, and the detailed
calculations of chimney emission are presented in Appendix 3.5. The meteorological
data adopted in AERMOD are detailed in Sections 3.6.30 to
3.6.31.
3.6.17 According
to the Guidelines on Assessing the ‘TOTAL’ Air Quality Impacts and Centralised
Environmental Database (CED) published by EPD, there are no major point
emission sources within 4 km of the Project boundary and no Specified Process
(SP) Licence within the assessment area.
Marine
emissions from Aberdeen Typhoon Shelter
3.6.18 The
vessels accessing the existing ATS and the Project would generate the marine
emission. NO2, RSP, FSP and SO2 are the key major marine
emission pollutants. For CO, the monitored CO background concentration is
notably low, measuring only approximately 4% of the AQO for the maximum 1-hour
CO concentrations, approximately 10% for the maximum 8-hour CO concentrations
and approximately 11% for the maximum 24-hour CO concentrations from 2021 to
2023. Consequently, CO is not considered a critical air pollutant of
concern for this Project. Various marine vessels such as pleasure
vessels, fishing vessels, Police Launches of the Hong Kong Police Force (HKPF)
and Adventure Ship
enter and leave the ATS. Based on the site observations
conducted on 7 August 2023, 13 November 2023, 18-19 November 2023 and 24 August
2024, no emissions are expected as the engines from all types of vessels such
as pleasure vessels, fishing vessels, police launches and adventure ship, are
turned off while moored or berthed at ATS. Additionally, no ferries were
observed mooring or berthing at ATS.
3.6.19 According
to the Plan of Passage Area in Aberdeen South Typhoon Shelter published by
the Hong Kong Marine Department (MD), the existing marine route (represented by
the grey shaded area in Appendix 3.6)
falls within the assessment area of the Project. Emissions from all
vessels are dispersed along the existing marine route and modelled as “POINT”
sources in AERMOD. The location of emissions (ID M24-M63 and M101-M102) along
the existing marine route outside the proposed expansion of ATS for rivertrade vessel (RTM), barge (TTBM), tugboat (TTTM), fast
launches (FLM) and small craft (SCM) are presented in Figure 3.5a.
3.6.20 According to the latest available information,
the ferry service time is as follows: 9:30 and 10:30 (departures from Aberdeen
to the temporary landing facility at Tai Shue Wan), and 19:00 and 20:00
(departures from the temporary landing facility at Tai Shue Wan to Aberdeen). Since the proposed Landing Facility at the proposed eastern breakwater
(hereinafter referred to as “The Proposed Landing Facility”) is schedule to be
completed by 2030, the ferry service will be relocated to the Proposed Landing
Facility.
3.6.21 Apart
from the Proposed Landing Facility, three existing landing facilities (HP015
Shum Wan Landing No.1, HP011 Po Chong Wan Landing Nol.1 and HP023 Ap Lei Chau
Landing No.5) and one Marine Police Aberdeen Base (MPAB) are located within the
assessment area, there are no other existing and planned landing points within
the assessment area of the Project. The locations of the existing/temporary
landing facilities and the Proposed Landing Facility are presented in Figure 3.4. The annual growth
rates of different vessel classes for hotelling are referenced to the Marine
Traffic Impact Assessment (MTIA) report. Vessel counts of each
existing/temporary landing facilities, as well as the Proposed Landing Facility
for hotelling, are provided in Tables D2 – D7 of Appendix 3.6. The marine traffic
data and annual growth rates adopted in the assessment have been endorsed by MD
and supplemented in Appendix 3.6.
Additional hotelling and maneuvering emissions from
vessels due to marine vessel growth within the assessment area are anticipated.
3.6.22 The
MTIA report contains the vessel count survey for the existing marine traffic,
indicating approximately 326 vessel movements per day entering and leaving the
ATS. The average annual growth rate of different vessel classes is taken into account in the marine emission calculations and
considered as the marine traffic during the operation phase. According to the
latest available information provided by CEDD, the Proposed Landing Facility is
expected to be completed in 2030 and will serve
various types of ferry and small craft vessels (e.g., ferry and kaito) to other key destinations/attractions and the
islands nearby in Southern District for the purpose of promoting marine
tourism, as well as ferry services between Aberdeen and proposed eastern
breakwater (re-route from the existing Tai Shue Wan Temporary Landing
Facility). The Proposed Landing Facility will serve 68 single-trip
vessels daily including 64 single-trip vessels for marine tourism from 10am to
6 pm and 4 single-trip ferries between Aberdeen and the Proposed Landing
Facility. These vessels will include ferry and small craft vessel types
(e.g., ferry and kaito). Emissions resulting from the hoteling and maneuvering
activities of these vessels were modelled as a “POINT” source. Figures 3.5d and 3.5f shows the marine emission sources during the
hotelling and maneuvering for these vessels. The routing of ferry services to Aberdeen is based on on-site
observations, while the routing for marine tourism is based on the advice of
the Project Engineer.
3.6.23 As advised by Marine Traffic
Consultant appointed under this study, for marine traffic
activities beyond 2040, it is assumed that there will be no major expansion of
container terminal development, or port facilities including typhoon shelters
and Public Cargo Working Areas (PCWA) in Hong Kong and marine traffic growth of
all vessel types is assumed to reach a peak in 2040. Therefore, the year 2040
is considered a worst-case scenario for marine emissions, based on the maximum
forecasted marine traffic. The annual growth rates of different vessel classes
are referenced to the MTIA report and provided in Table D1 of Appendix 3.6. The marine traffic
data and annual growth rates adopted in the assessment have been endorsed by MD
and supplemented in Appendix 3.6.
3.6.24 Due to the lack of available
information on the potential marine route within, as well as entering and
leaving the expanded ATS, indicative marine routes have been assumed, subject
to the future expanded typhoon shelter arrangement. For the worst-case scenario in the
assessment, the marine route is assumed to be in close
proximity to the identified representative ASRs. Upon entering and
leaving ATS (i.e., emission ID M1 – M23), the assumed marine route is near
Ocean Park, as shown in Figure 3.5a. Within the expanded ATS, one of the assumed marine routes (depicted in
Figure 3.5c) is situated on
the eastern side of the Project and has a higher impact on the identified ASRs
such as A1, A4, A5, A6, A7, A8, A9, A10, and A11 on the eastern side.
Similarly, another assumed marine route (depicted in Figure 3.5b) is located on the
western side of the Project and has a higher impact on the identified ASRs such
as A2, A3a and A3b on the western side. For rivertrade
vessel (RTM), barge (TTBM), tugboat (TTTM), fast launches (FLM) and small craft
(SCM), accounting for 100% of the total number of vessels, navigate along the
proposed marine routes. In other words, 100 % of the vessels navigate the
eastern side of the proposed marine route and an additional 100% of vessels
navigate the western side of the proposed marine route as
a conservative scenario. Emissions from all vessels are dispersed along the
assumed marine routes within the Project and modelled in AERMOD as “POINT”
sources. Emissions during hoteling at the piers (i.e., Sham Wan Landing, Po
Chong Wan Landing, Ap Lei Chau Landing, MPAB and the Proposed Landing Facility)
were modelled as “POINT” source with AERMOD. The parameters such as the exit
temperature, stack height, are referenced to the approved Lei Yue Mun
Waterfront Enhancement Project EIA Report (Register No.: AEIAR-219/2018) and
on-site observation or other information.
3.6.25 According
to the available information from Adventure ship, the vessel operates from 9:30
am to 4:30 pm, with two round trips passing through the ATS. The routing of maneuvering within the existing
ATS is based on on-site observations. Due to the lack of information regarding
potential marine routes within the expanded ATS, a conservative approach is
adopted, as outlined in Section 3.6.24. This approach involves using two
marine routes located on the eastern and western sides of the Project. The
marine emission sources during maneuvering for the
Adventure Ship are illustrated in Figure 3.5e. There is no hotelling of adventure ships within the assessment area, as confirmed by the site visit.
3.6.26 With
reference to the Study on Marine Vessels Emission Inventory (MVEIS) by the Hong
Kong University of Science and Technology (HKUST), marine emission is estimated
by an activities-based approach. The emission factors were derived in units of
work (gram per kilowatt-hour), dependent on the fractional load of the
equipment during different vessel activity modes. The calculation can be
summarised below:
Emission = P × FL × T × EF
where P is the installed power of equipment;
FL is a fractional load of equipment in a specific mode;
T is operation time-in-mode; and
EF is a fractional load emission factor of equipment.
3.6.27 Typical
power equipment installed on marine vessels are Main Engine (ME) for
propulsion, Auxiliary Engine (AE) for electricity and Auxiliary Boiler (AB) for
fuel pre-heating and pumping. Subject to the vessel type, different
combinations of engines are equipped on a vessel. Typical engine power rating,
engine type, and fuel type of each vessel type were adopted from MVEIS or other
relevant information.
3.6.28 Typical
engine load factor by vessel type and by operation mode refers to MVEIS. The
engine load factor of the marine source was then determined according to its
vessel type and its operation mode. The time-in-mode was estimated by the
distance and vessel speed travelled in the corresponding mode (i.e., Fairway
Cruise – over 12 knots; Slow Cruise – 8 to 12 knots; Maneuvering
– 1 to 8 knots and Hoteling – below 1 knot). According to the Shipping and Port
Control Regulations (CAP 313A), the maximum permitted speed at the entrance to
or within a typhoon shelter is 5 knots. As such, for a route within the typhoon
shelter area, the average travelling speed is assumed to be 5 knots.
3.6.29 Stack
height, diameter, exit temperature, and exit velocity of the vessels are made reference to the stack parameters for vessels in the
approved EIA Lei Yue Mun Waterfront Enhancement Project (Register No.:
AEIAR-219/2018) and on-site observation or other information. The detailed
calculation of the marine emission is presented in Appendix 3.6.
3.6.30 Hourly meteorological conditions for
Year 2019 including wind data, temperature, relative humidity, pressure, cloud
cover, and mixing height, were extracted from the Weather Research and
Forecasting (WRF) meteorological data under PATH v3.0 system was adopted for
the meteorological input to AERMET (the meteorological pre-processor of
AERMOD). The minimum wind speed was capped at 0.5 metre per second. The mixing
height was capped between 119 metres and 2009 metres according to the
observation in Year 2019 by Hong Kong Observatory (HKO). The height of the
input data was assumed to be 9 metres above ground for the first layer of the
WRF data as input. The input file to AERMET has been
obtained from EPD’s SAMP v2.1. The output files from AERMET were also obtained
from SAMP, which are subsequently used as input in AERMOD.
3.6.31 Surface characteristic parameters
such as albedo, Bowen ratio, and surface roughness are required in the AERMET
(the meteorological pre-processor of AERMOD). The land use
characteristics of the surrounding are classified, and these parameters of each
land use are then determined by default on SAMP according to its land use
characteristics. The detailed assumptions are
discussed in Appendix 3.7.
Given that the Project is situated in a complex terrain, the 'terrain' option and
urban mode were utilised in AERMOD, and the base elevation of receptors and
emission sources were inputted.
Conversion of NOx to NO2
3.6.32 The conversion from NOx to NO2 is necessary to
compare the operation phase cumulative results against AQOs. The conversion
method follows the approaches stated in the ‘Guidelines on Choice of Models and
Model Parameters’ published by EPD. Two approaches, namely Ozone Limiting
Method and Jenkin Method, were adopted for the conversion from NOx
to NO2.
Ozone Limiting Method for Short-term Cumulative
NO2 Assessment
3.6.33 For
the short-term cumulative NO2 assessment (i.e., predictions of
hourly average NO2 concentration), Ozone Limiting Method (OLM) was
adopted for conversion of NO from vehicle-related sources (i.e., emissions from
open roads, coach parking sites and shuttle bus termini in Water World Ocean
Park Hong Kong and Fullerton Ocean Park Hotel) and NOx from industrial and
marine sources to NO2 based on the predicted O3 level
from PATH v3.0. According to the Heathrow Airport EIA report, the
initial NO2/NOx ratios of marine and industrial emission sources are
10%. The NO2/NOx conversion was
calculated as follows:
[NO2]predicted
= [NO2]vehicular +
0.1 ´ [NOx]marine/chimney
+ MIN {[NO]vehicular + 0.9 ´ [NOx]marine /chimney, or (46/48) ´ [O3]PATH}
where
|
[NO2]predicted
|
is the predicted NO2
concentration
|
|
[NO2]vehicular
|
is the sum of predicted initial NO2
concentration from open roads, coach parking sites and shuttle bus termini in Water World Ocean Park
Hong Kong and Fullerton Ocean Park Hotel
|
|
[NOx]marine/chimney
|
is the sum of predicted initial NOx
concentration from the marine and industrial emission sources
|
|
[NO]vehicular
|
is the sum of predicted initial NO
concentration from open roads, coach parking sites and shuttle bus termini in Water World Ocean Park
Hong Kong and Fullerton Ocean Park Hotel
|
|
MIN
|
means the minimum of the two values within
the brackets
|
|
[O3]PATH
|
is the representative O3
from PATH concentration (from other contribution)
|
|
(46/48)
|
is the molecular weight of NO2 divided by the molecular
weight of O3
|
3.6.34 For
the long-term cumulative NO2 assessment (i.e., predictions of annual
average NO2 concentration), Jenkin method was adopted for the
conversion of cumulative NOx to NO2 by using the
functional form of an annual mean of NO2-to-NOx with
reference to the Review of Methods for NO to NO2 Conversion in
plumes at short ranges.
The mentioned functional form is referenced from Jenkin, 2004a and is presented as follows:

where
|
[NO2]
|
is the NO2 concentration
|
|
[NOx]
|
is the NOx concentration
|
|
[OX]
|
is the sum of NO2 concentration
and O3 concentration (i.e. [OX] = [NO2] + [O3])
|
|
J
|
is the photolysis rate of NO2
|
|
k
|
is the rate coefficient for reaction between
NO and O3
|
3.6.35 The annual mean data obtained from
the EPD’s AQMS, including the Southern general station, Tap Mun general
station, and three roadside stations (Causeway Bay, Central, and Mong Kok),
were analysed using the functional form provided above. The Southern general
station was initially chosen as the representative station due to its
proximity. However, since the Southern general station was commissioned on
10 July 2020, data from the Southern general station was also available
starting from 2021. The Tap Mun general station and three roadside stations
were included to cover a wider range of NOx concentration. The function from
curve would fit the annual mean data when [OX] = 95.57 µg/m3 and J/K = 17.114 µg/m3. The obtained
functional form curve was adopted for the cumulative annual average NOx
to NO2 conversion. As shown in Appendix 3.8, the curve is higher
than all the annual mean data obtained from AQMS and on-site measurement data,
underestimation of the annual average NO2 concentration is not
expected. The cumulative annual average NOx
to NO2 conversion equation for this assessment was calculated as
follows:

where
|
[NO2] c
|
is the predicted cumulative NO2
concentration in µg/m3
|
|
[NOx] c
|
is the predicted cumulative NOx
concentration (i.e., the sum of the total predicted NOx concentration from
AERMOD and PATH v3.0) in µg/m3
|
Cumulative
Air Quality Impact
3.6.36 Cumulative
air quality impacts upon ASRs were derived from the sum of predictions by local
air quality models (i.e. AERMOD model) and background concentration from PATH
v3.0 for Year 2030 on hour-by-hour basis.
3.6.37 Time-averaged
results, namely hourly, daily and annual, are derived from the cumulative
hour-by-hour results. For annual average, the sum of all hourly concentrations
is divided by the number of hours during the year to obtain the annual-averaged
concentration. The air quality impact upon ASRs is evaluated by respective
concentration limits specified in the AQO. For daily average, cumulative
daily-averaged results at each ASR amongst 365 days are ranked by the
concentration and the ranked daily-averaged concentrations are compared with
the maximum allowable concentration to determine the number of exceedances
throughout a year. The air quality impact upon ASRs was evaluated by number of
exceedances per annum against the number of exceedances allowed as specified in
the AQO or EIAO-TM for hourly and daily averaged result.
3.6.38 According to “Guidelines on the
Estimation of 10-min average SO2 Concentration for Air Quality
Assessment in Hong Kong”, the 10-min SO2 concentration is determined
by multiplying the 1-hour average of the SO2 concentrations by the
conversion factors specific to corresponding stability classes, as provided in Table 3.7.
Table 3.7
Stability-dependent Multiplicative Factors
|
Stability Class
|
A
|
B
|
C
|
D
|
E
|
F
|
|
Conversion
Factor
|
2.45
|
2.45
|
1.82
|
1.43
|
1.35
|
1.35
|
3.7
Prediction
and Evaluation of Environmental Impacts
Construction
Phase
3.7.1 As mentioned in Sections 3.5.1-3.5.4, the potential air quality
impact from the construction activities would be limited during the
construction phase. Hence, there would be no adverse air quality impact
anticipated from the works area to the surrounding ASRs. Nevertheless, air
quality mitigation measures recommended in Section 3.8 and mitigation measures stipulated in Air
Pollution Control (Construction Dust) Regulation shall be implemented to
minimise the potential air quality impact from the construction of the Project.
3.7.2 The potential odour impact from the dredging activities would be
short-term as the dredged material is transported away from the Project site
once excavated and is appropriately covered before transportation. As such,
adverse odour impact from the dredged material is not expected. As mentioned in
Section 3.5.4, the emissions from PMEs and dump trucks are considered
minor. The travel distance of dump trucks would be minimised, and the use of
highways would be maximised as much as possible to shorten the duration of
transport. In addition, vehicles loaded with the dusty materials will be
covered by clean and impervious sheeting to minimise air quality impact to the
nearby ASRs before leaving the work sites. Hence, adverse air quality
impact arising from the use of PME and dump trucks to the surrounding ASRs is
not anticipated.
3.7.3
For
the marine traffic arising from the Project, based on the advice from Project
Engineer, it is assumed that maximum 24 vessels will operate per day during the
peak construction period of approximately 200 days. This includes 9 hopper
barges, 10 dump lighter barges, 1 DCM barge (which is not propelled by an
engine), and 4 tugboats that facilitate the movement of the barges but
will not be stationed on-site. The separation distance from the
construction vessel to the nearest ASR (A10b) is approximately 421m (distance
shown in Figure 3.3a). Another period, representing the minimum number of construction vessels
employed, will last approximately 100 days, which a
maximum of 9 vessels will operate daily. This
includes 3 dump lighter barges, 3 hopper barges and 1 DCM barge, which are not
engine-propelled, along with 2 tugboats that assist in moving the barges but
will not be stationed on-site. The separation distance to the
nearest ASR (A10a) is approximately 109 m (as shown in Figure 3.3b). These two
construction periods are scheduled to occur within a specific timeframe in the
overall construction timeline from 2026 to 2030. The number of construction
vessels utilised during all construction periods and the shortest separation
distance from construction vessels to the nearest ASRs during all construction
periods are given in Section 3.5.3. According to Section 3.5.2,
a maximum of 3 barges would be used per day for the transfer of the dredged
materials and another 3 barges would be stationed on-site to assist with the
dredging work. Given the large separation distance between the dredging
extent and the nearest ASR (approximately 322m), and with the implementation of the requirements and measures
stipulated in the in the Air Pollution Control (Non-Road Mobile Machinery
(NRMM)) (Emission) Regulation and Air Pollution Control (Fuel
Restriction) Regulation, adverse air quality impact associated with barges
used for dredging works is not expected. Vessels are not expected to be all
present at the same time due to the phasing of construction activities, and
idle vessels shall be avoided in the construction area. Effective
planning of construction vessel activities can help minimise the number of
vessels on site, it is unlikely that air quality impact from construction
vessels will be adverse.
Operation
Phase
3.7.4 The cumulative air quality impacts at the representative ASRs have been
evaluated. Detailed assessment results of all relevant assessment heights of
the identified representative ASRs are provided in Appendix 3.9.
3.7.5 According to the predicted cumulative NO2, RSP, FSP and SO2
concentrations at the representative ASRs during the operation of the Project,
the prediction indicated that the 10th highest daily average and the
annual average of RSP concentrations, the 19th highest daily average
and the annual average of FSP concentrations and the 19th highest
hourly average, 10th highest daily average and the annual
average of NO2 concentrations, the 4th highest
10-min and daily SO2 concentrations at all representative ASRs would
comply with both prevailing and proposed AQOs. The predicted results are
presented in Table 3.8.
Table 3.8 Predicted
Cumulative Concentrations at Representative Air Sensitive Receivers During the
Operation Phase
|
ASR
|
NO2 Concentration (µg/m3)
|
RSP Concentration (µg/m3)
|
FSP Concentration (µg/m3)
|
SO2 Concentration (µg/m3)
|
|
19th Highest Hourly Average
|
10th Highest Daily Average
|
Annual Average
|
10th Highest Daily Average
|
Annual Average
|
19th Highest Daily Average
|
Annual Average
|
4th Highest 10-min
Average
|
4th Highest Daily Average
|
|
Prevailing AQO
|
200
|
-
|
40
|
100
|
50
|
50
|
25
|
500
|
50
|
|
Proposed AQO
|
200
|
120
|
40
|
75
|
30
|
37.5
|
15
|
500
|
40
|
|
Existing
ASRs
|
|
A1
|
72 - 106
|
33 - 43
|
14 - 19
|
49 - 50
|
18 - 19
|
28
|
11
|
23 - 24
|
6
|
|
A2
|
80 - 97
|
40 - 42
|
16 - 20
|
50
|
18
|
28
|
11
|
25
|
7
|
|
A3a
|
106 - 116
|
44 - 45
|
22 - 23
|
50
|
18 - 19
|
28 - 29
|
11
|
25
|
7
|
|
A3b
|
126 - 146
|
49
|
23 - 24
|
50
|
19
|
29
|
11
|
25
|
7
|
|
A4
|
98 - 103
|
47
|
20
|
50
|
18
|
28
|
11
|
28
|
7
|
|
A5
|
81 - 87
|
37 - 40
|
15 - 16
|
50
|
18
|
28
|
11
|
23
|
6
|
|
A6
|
77 - 80
|
35 - 36
|
14 - 15
|
50
|
18
|
28
|
11
|
23
|
6
|
|
A7
|
91 - 104
|
38 - 40
|
15 - 16
|
50
|
18
|
28
|
11
|
23
|
6
|
|
A8
|
97 - 110
|
44 - 48
|
17 - 19
|
50
|
18
|
28
|
11
|
25
|
7
|
|
A9
|
76
|
32
|
13
|
49
|
18
|
28
|
11
|
24
|
6
|
|
A10a
|
88 - 125
|
45 - 48
|
18 - 21
|
50
|
18
|
28
|
11
|
25 - 27
|
7
|
|
A10b
|
88 - 121
|
45 - 50
|
18 - 24
|
50
|
18
|
28
|
11
|
25 - 26
|
7
|
|
A11
|
91 - 97
|
40
|
18
|
50
|
18
|
28
|
11
|
24
|
6
|
|
Planned
ASRs
|
|
PA01
|
114 - 120
|
42 - 43
|
-
|
50
|
-
|
28
|
-
|
27
|
7
|
|
PA02
|
116 - 128
|
42
|
-
|
50
|
-
|
28
|
-
|
26 - 27
|
7
|
|
PA03
|
123 - 138
|
42
|
-
|
50
|
-
|
28
|
-
|
26
|
7
|
Note:
[1] Long-term AQOs (i.e., annual NO2, annul RSP and
annual FSP) are not applicable to PA01, PA02 and PA03 in consideration of short
retention time at these kinds of uses.
3.7.6
According
to the discrete results listed in Appendix 3.9, the worst affected levels for all ASRs, except A10a and A10b, would be
1.5 mAG and 5 mAG.
For ASRs A10a and A10b, the worst affected level for the 19th
highest hourly NO2 would be 15 mAG.
Contour plots are presented to illustrate various pollutant concentrations
including the 19th highest hourly average, the 10th
highest daily average and annual average NO2 concentrations, the 10th
highest daily average and annual average RSP concentrations, 19th
highest daily average and annual average FSP concentrations, as well as 4th highest
10-min average and daily average SO2 concentrations within the
assessment area at the worst affected level. These plots at the worst affected
levels, are presented in Figure
3.6 to Figure 3.23 for 1.5 mAG and 5 mAG,
Figure 3.27 to Figure 3.29
for the pollutant of NO2
at 15 mAG. To
evaluate potential exceedances of NO₂ at 10 mAG, the 19th
highest hourly NO₂, the 10th highest daily NO₂, and the annual average NO₂ at
10 mAG are presented in Figure 3.24 to Figure 3.26.
3.7.7 Under the prevailing AQOs and the proposed AQOs, exceedance zones were
identified in the contour plots for the 19th highest hourly NO2
at 1.5 mAG, 5 mAG and
10 mAG, as well as for the
annual average NO2 at 1.5 mAG, 5 mAG, 10 mAG and 15 mAG. The occurrences of exceedance
zones in the contour plots are summarised in Table
3.9.
Table 3.9 Summary of Exceedance Zone Occurrences in the
Contour Plots
|
Pollutant [2]
|
Assessment Height (mAG)
|
|
1.5
|
5
|
10 [3]
|
15 [4]
|
|
Figures 3.6 – 3.14
|
Figures 3.15 – 3.23
|
Figures 3.24 – 3.26
|
Figures
3.27 – 3.29
|
|
RSP
|
10th Highest Daily
|
Prevailing AQO
|
|
|
N/A
|
N/A
|
|
Proposed AQO
|
|
|
N/A
|
N/A
|
|
Annual
|
Prevailing AQO
|
|
|
N/A
|
N/A
|
|
Proposed AQO
|
|
|
N/A
|
N/A
|
|
FSP
|
19th Highest Daily
|
Prevailing AQO
|
|
|
N/A
|
N/A
|
|
Proposed AQO
|
|
|
N/A
|
N/A
|
|
Annual
|
Prevailing AQO
|
|
|
N/A
|
N/A
|
|
Proposed AQO
|
|
|
N/A
|
N/A
|
|
NO2
|
19th Highest Hourly
|
Prevailing AQO
|
✔
|
✔
|
✔
|
|
|
Proposed AQO
|
✔
|
✔
|
✔
|
|
|
10th Highest Daily [5]
|
Prevailing AQO
|
N/A
|
N/A
|
N/A
|
N/A
|
|
Proposed AQO
|
|
|
|
|
|
Annual
|
Prevailing AQO
|
✔
|
✔
|
✔
|
✔
|
|
Proposed AQO
|
✔
|
✔
|
✔
|
✔
|
|
SO2
|
4th Highest 10-mins
|
Prevailing AQO
|
|
|
N/A
|
N/A
|
|
Proposed AQO
|
|
|
N/A
|
N/A
|
|
4th Highest Daily
|
Prevailing AQO
|
|
|
N/A
|
N/A
|
|
Proposed AQO
|
|
|
N/A
|
N/A
|
Notes:
[1]
“✔” indicates that an exceedance zone was identified for
specific pollutants.
[2]
The criteria for the prevailing AQO and the proposed AQO are detailed in Table 3.1
and Table 3.2,
respectively.
[3]
To evaluate potential exceedances of NO₂ at 10 mAG,
the 19th highest hourly NO₂, the 10th highest daily
NO₂, and the annual average NO₂ at 10 mAG
are presented in Figures
3.24 to 3.26. Contours for RSP, FSP, and SO₂ are not plotted at
10 mAG.
[4]
According to Section 3.7.6, the worst affected level for the 19th
highest hourly NO2 is 15 mAG.
Contours for RSP, FSP, and SO2 are not plotted at 15 mAG.
[5]
The 10th highest daily NO2 is applicable only in the
proposed AQO.
3.7.8 According to Table 3.9, the
exceedance zones in the contour plots were identified. It is confirmed that no
air sensitive uses shall be located within the exceedance zones. Therefore, no
adverse air quality impact is anticipated from the operation of the Project.
3.8
Mitigation of Adverse Environmental Impacts
Construction Phase
3.8.1 The approved NRMMs under NRMM Regulation (excluding exempted NRMMs)
would be used on site and NRMMs supplied with mains electricity instead of
diesel-powered shall be adopted as far as possible to minimise the potential
emission from NRMMs.
3.8.2
In
addition, air quality mitigation measures stipulated in the Air Pollution
Control (Construction Dust) Regulation and good site practices listed below
shall be carried out to further minimise construction air quality impact.
• Use of regular watering to reduce dust emissions from
exposed site surfaces and unpaved roads, particularly during dry weather.
• Use of frequent watering for particularly dusty
construction areas and areas close to ASRs.
• Side enclosure and covering of any aggregate or dusty
material storage piles to reduce emissions. Where this is not practicable
owing to frequent usage, watering shall be applied to aggregate fines.
• Open stockpiles shall be avoided or covered.
Where possible, prevent placing dusty material storage piles near ASRs.
• Tarpaulin covering of all dusty vehicle loads
transported to, from and between site locations.
• The engine of the PMEs during idling shall be switched
off.
• Provision of wind shield and dust extraction units or
similar dust mitigation measures at the loading area of barging point, and use
of water sprinklers at the loading area where dust generation is likely during
the loading process of loose material, particularly in dry seasons/ periods.
• Provision of not less than 2.4 m high hoarding from
ground level along site boundary where adjoins a road, streets or other
accessible to the public except for a site entrance or exit.
• Where possible, routing of vehicles and positioning of
construction plant should be at the maximum possible distance from ASRs.
• Instigation of an environmental monitoring and
auditing program during the construction phase in order to
enforce controls and modify method of work if dusty conditions arise and to ensure no adverse air quality impact during Construction phase.
• Locate all the dusty activities away from any nearby
ASRs as far as practicable.
• For construction vessels, the number of trips would be
monitored and minimised and vessel travelling route would be kept away from the
ASRs as far as possible.
• Engine of construction vessels shall be switched off
while not in use.
• All malodorous materials shall be placed as far as
possible from any ASRs.
• The stockpiled malodorous materials shall be covered
entirely by plastic tarpaulin sheets.
• The malodorous materials shall be removed from site as
soon as possible and shall not be stockpiled overnight at the site.
• Dredged materials onto the barges should be properly
covered as far as practicable to minimise the exposed area and potential
fugitive dust and odour emissions during its transportation.
3.8.3 With the implementation of the mitigation measures stipulated in the Air
Pollution Control (Construction Dust) Regulation and the above air quality
mitigation measures, adverse construction air quality impact would not be
anticipated.
Operation
Phase
3.8.4 No adverse air quality impact during the operation of the Project is
anticipated. Mitigation measures are thus considered not necessary during the
operation phase. No air sensitive use shall be located within the exceedance
zones identified in the Contour plots.
3.9
Evaluation of Residual Impacts
Construction
Phase
3.9.1 With the implementation of the mitigation measures as stipulated in the
Air Pollution Control (Construction Dust) Regulation together with the
recommended air quality control measures and good site practices on the work
sites, no adverse residual impact would be expected from construction of the
Project.
Operation
Phase
3.9.2 No adverse residual impact is expected during the operation phase of the
Project.
3.10
Environmental Monitoring and Audit
Construction
Phase
3.10.1
Environmental
monitoring and audit (EM&A) for potential air quality impacts shall be
conducted during construction phase so as to check
compliance with the legislative requirements. Details of the monitoring
and audit programme are contained in a stand-alone EM&A Manual.
3.10.2 Regular
site audit for potential air quality and odour impact, dust monitoring is recommended to be
conducted during the entire construction phase of the Project to ensure the air
quality and odour mitigation measures and the mitigation measures stipulated in
Air Pollution Control (Construction Dust) Regulation are implemented in order
and to ensure no adverse air quality and odour impact at the ASRs.
Operation
Phase
3.10.3 No
adverse residual air quality impact arising from the Project is anticipated
during the operation of the Project. Therefore, the EM&A works for the
operation phase are considered unnecessary.
3.11
Conclusion
Construction
Phase
3.11.1 The potential air quality impacts which may arise from
the construction works of the Project include filling for the proposed
breakwater, construction of the proposed wave wall in the form of floating breakwater, construction of the proposed land access, as well as the
modification of existing eastern and western breakwaters, and material
handling. With the implementation of mitigation measures specified in the
Air Pollution Control (Construction Dust) Regulation together with the
recommended air quality mitigation measures, good site practices, and EM&A
programme, no adverse air quality impact at
ASRs is anticipated due to the construction activities of the Project.
Operation
Phase
3.11.2 Cumulative
air quality impact arising from vehicular emission from open road, emission
associated with parking site/termini, industrial and marine emissions within
the assessment area, as well as background concentrations, has been assessed
for the operation phase of the Project. The results concluded that the
predicted cumulative air quality concentrations on the identified ASRs comply
with both the prevailing and the proposed AQOs during the operation phase and no air sensitive use shall be located within the exceedance
zones identified in the Contour plots. As such, adverse air quality
impact due to the operation of the Project is not anticipated.