1 Introduction

1.1 Project Background

1.1.1 The title of this Project is “Provision of Crematorium at Wo Hop Shek Cemetery” (hereafter named “the Project”).

1.1.2 The body cremation services in Hong Kong are mainly provided by the Food and Environmental Hygiene Department (FEHD). With the growth in overall population and changes in demographic profile, the projected demand for cremation service in Hong Kong is expected to continue to increase steadily in the next 20 years. In order to cope with increasing demand for cremation services, a new crematorium is proposed at the Wo Hop Shek Cemetery (WHS Cemetery).

1.1.3 FEHD proposes to develop a new crematorium within the existing WHS Cemetery in the North District. The area of the Project Site is approximately 3ha. It includes the proposed Wo Hop Shek Crematorium Site (approximately 2ha, hereafter called the proposed WHS Crematorium Site) and other works associated with the proposed crematorium within the Project Boundary in Figure 1.1.

1.1.4 Architectural Services Department (ArchSD) acts as the works agent for FEHD and is responsible for the project management, design and implementation of the Project. FEHD will be responsible for management and operation of the new crematorium. In April 2022, Atkins China Limited (Atkins) was commissioned by ArchSD to undertake an Environmental Impact Assessment (EIA) study for the Project under Environmental Consultancy Services for Provision of Crematorium at Wo Hop Shek Cemetery (Programme No. 035NB).

1.2 Site Location and History

1.2.1 The WHS Cemetery, opened in 1950 and the largest public cemetery in Hong Kong, spans approximately 220 hectares. The proposed WHS Crematorium Site is located entirely within the WHS Cemetery and its Project Boundary is within Permanent Government Land Allocation (PGLA) No. GLA-DN 81, which has been granted to FEHD for cemetery use.

1.2.2 The Project Site is located at about 300m from Kiu Tau Road and 240m from the existing WHS Crematorium and is accessible via WHS Road (Figure 1.1). It is situated in a vegetated trough and surrounded by slopes on three sides, enhancing its seclusion (see Diagram 1 below). The natural terrain and surrounding vegetation, which include mixed woodland, shrubland, and grassland, will help minimize the Project’s visual impacts to WHS Cemetery visitors and nearby hikers, as well as shield the Project Site from the view of high-rise residential developments to the north, such as Wah Ming Estate and Fai Ming Estate. The nearest residential noise/ air sensitive receivers, i.e., village houses in Nam Wa Po, are located at about 370m from the Project Site.

Diagram 1 Project Site and Surrounding Slopes

1.3 Scope of the Environmental Impact Assessment Study

1.3.1 The Project comprises construction and operation of a new crematorium, which is classified as a Designated Project (DP) by virtue of Item N.4 of Schedule 2, Part I of the Environmental Impact Assessment Ordinance (EIAO), which specifies “A crematorium”.

1.3.2 In accordance with Section 5(1)(a) of the EIAO, FEHD, the Project Proponent, submitted a Project Profile (No. PP-657/2023) to the Director of Environmental Protection (DEP) to apply for an Environmental Impact Assessment (EIA) Study Brief on 19 July 2023. Pursuant to Section 5(7)(a) of the EIAO, the DEP issued to FEHD an EIA Study Brief No: ESB-362/2023 on 28 August 2023 (the Study Brief) to carry out an EIA study for the Project.

1.3.3 This EIA study was conducted in accordance with the Study Brief and the Technical Memorandum on Environmental Impact Assessment Process (EIAO-TM) requirements to provide information on the nature and extent of environmental impacts arising from construction and operation of the Project and to confirm the environmental acceptability of the Project.

1.4 Purpose of this Executive Summary

1.4.1 This Executive Summary (ES) highlights the key information and findings of the EIA Study.

2 Project Description

2.1 Need for the Project

2.1.1 FEHD currently manages 34 body cremators (ten in Cape Collinson, six in Diamond Hill, eight in Wo Hop Shek, four in Fu Shan, four in Kwai Chung, and two in Cheung Chau). About 57,290 cremation sessions are available each year under regular operation of FEHD facilities. The annual average numbers of deaths and cremations are estimated to be around 60,000 and 57,000, respectively between year 2019 and year 2038.

2.1.2 On the supply side, the serviceable life span of cremators is about 40,000 cremation cycles according to the supplier of cremators. The cremators in the existing Wo Hop Shek Crematorium at Kiu Tau Road (hereafter called the existing WHS Crematorium to differentiate the proposed WHS Crematorium under this Project) and the Cape Collinson Crematorium were reprovisioned in 2013 and 2015, respectively. The cremators in the crematoria in Cheung Chau, Kwai Chung, Fu Shan and Diamond Hill have been in use since years 1991, 2003, 2004 and 2007, respectively. When the cremators have reached the end of their expected service life, their stability will deteriorate. In the normal course, reprovisioning projects for crematoria need to be kicked off at suitable junctures. During a typical 3-4 years’ course from decommission of an old facility to completion of a new one, there will be a reduction in the total number of cremation sessions available. As an overall picture, it is anticipated that there will be a shortage in the number of available sessions from year 2025 to year 2027 due to reprovisioning of existing cremators in Kwai Chung and from year 2031 onwards due to reprovisioning of existing cremators in other crematoria.

2.1.3 Given the increasing demand and the need for supply reprovisioning, planning and/ or implementing crematorium projects is in progress to ensure no service gaps. The Project is the next in the pipeline to provide ten new cremators at the WHS Cemetery for commissioning in year 2030, adding approximately 21,600 cremation sessions per annum.

2.2 Scenarios “With” and “Without” the Project

2.2.1 Without the implementation of the proposed Project, Hong Kong faces a significant challenge in meeting the growing demand for cremation services. Due to the reprovisioning of existing crematoria facilities and an increasing need over time, the current capacity is insufficient. Without the Project, the existing crematorium in the WHS Cemetery area would become overloaded, and it would be difficult to meet FEHD’s commitment to provide unallocated cremation sessions within 15 days. This would lead to prolonged waiting times for cremation, which would likely be deemed unacceptable by the community. Additionally, in the absence of the Project, the environmental state of the Project Site would remain unchanged, consisting of mixed woodland, shrubland, and grassland, alongside disused terraced graveyards.

2.2.2 On the other hand, with the Project, the fallow Project site at the WHS Cemetery would be transformed into a modern crematorium with service halls. This development would not only increase the cremation capacity to meet the rising demand but also enhance the environmental aesthetics of the area through thoughtful landscaping. The planned retention of existing trees and the addition of new plantings aim to improve the greenery of the site. By effectively increasing the cremation capacity, a considerable number of applications for cremation sessions will therefore likely be met within the present pledge of 15 days. This would prevent the overloading of cremation services and make the waiting time for the bereaved families more acceptable.

2.3 Consideration of Alternatives/ Options

2.3.1 Regarding the project location, alternative remote areas within Hong Kong have been explored for the potential crematorium development, aiming to minimize public objections and allow for more flexible planning due to fewer structural constraints. However, the explored sites pose different challenges in terms of accessibility and environmental impacts, including traffic noise, visual disturbances, air emissions, habitat loss and pollution etc. Developing these sites would require significant time for infrastructure development and/ or zoning adjustments, leading to delays in meeting the growing demand for cremation services. In terms of extension at other existing crematoria in Hong Kong, they are already maximized in capacity or face physical limitations for expansion, making it difficult to address the increasing need for cremation services promptly and adequately.

2.3.2 In addition to alternative locations, several alternatives/ options in design and layout of the Project have also been considered. The preferred locations, design and layout for the Project to be taken forward for design and construction have been selected according to various engineering and environmental factors. Table 2.1 summarises the environmental benefits and dis-benefits of the alternatives/ options.

2.3.3 The trough placement of the proposed WHS Crematorium minimizes the Project’s visual impact. The building layout efficiently utilizes the site's topology, reducing excavation and waste production. The optimized chimney heights blend with natural terrain. Also, a mix of standard and larger cremators balances the need to handle heavier bodies and promoting energy efficiency, reducing air pollutant emissions. With the Project, part of the WHS Cemetery will be transformed into a modern, green-centric crematorium, increasing capacity to meet the rising demand, maintaining a swift service pledge, and preventing overload on the existing crematorium facilities.

Table 2.1 Summary of Considered Alternative Development Parameters and Environmental Benefits and Disbenefits

Development Parameter	Considered Option (* indicates the preferred option)	Environmental Benefit	Environmental Disbenefit	Reason(s) for not Selected as Preferred Option
	New sites in more remote areas	- Less constraints on building structure design and more scope for flexible planning	- Longer construction traffic movement and hence more associated vehicular emissions and traffic noise - Longer commutes for the staff and visitors, resulting in more vehicular emissions to the environment and newly introduced traffic noise during operation - Greater habitat loss due to extensive site formation works - Visual impact of the new crematorium facility	- New sites in remote areas pose significant access challenges for the general public, leading to longer commuting times and increased vehicular emissions. - Developing a new crematorium in remote areas introduces several environmental concerns, including traffic noise, visual impact, air emissions, and potential habitat loss due to construction. These impacts, while possibly mitigable, add complexity and potential delays to the Project. - Establishing sufficient transport and infrastructural facilities in remote areas would be time-consuming. Additionally, resolving land use zoning issues that might arise because these areas are not pre-designated for crematorium use would further delay development, making it impractical to meet the urgent demand for cremation services.
	New site at the bottom of a trough area, inside the Wo Hop Shek Cemetery *()**	- The trough location partially screens out visual impact - Minimise the extent of slope cutting and site formation works - Generate less amount of inert and non-inert construction and demolition (C&D) materials - Fugitive dust generated during construction stage less easily disperse and affect the nearby sensitive receiver - There is an existing access road leading to the Project site. Less new road works is required and hence less associated environmental pollution	- Less efficient dispersion of cremator emissions but can still meet the Hong Kong Air Quality Objectives (AQO)	- Not Applicable.
	Extension at other existing crematorium sites	- Not applicable.	- Maximum site utilization reached and/ or constrained by site physical and environmental conditions	- Existing crematoria in Hong Kong are either fully utilized in terms of site capacity or are physically constrained, preventing significant expansions. - Any possible expansion at existing sites would be minimal and not timely enough to address the increasing demand for cremation services effectively.
Design – Building Layout	Cremator room on 1/F and service halls scattered around *()**	- Make use of site topology and avoid extensive excavation work - Generate less amount of inert and non-inert C&D materials - Substantially reduces the amount of deep excavation	- Slightly higher visual intrusion	- Not Applicable.
Design – Building Layout	Ten cremators grouped together on the ground floor	- Better operation and higher efficiency in internal circulation space	- Larger floor area required and hence more excavation on the existing slopes - Greater habitat loss and generation of construction waste	- The site is located at the bottom of a trough surrounded by slopes which necessitates large-scale excavation if all ten cremators were grouped together on the ground floor. Such an arrangement would require a significant alteration of the landscape to accommodate a large cremator plant room. - Grouping the cremators together would not only require deeper and more extensive excavation but would also lead to greater habitat loss, increased generation of waste and environmental pollution. These impacts arise from the need to significantly alter the existing slopes to fit the required infrastructure.
Design – Chimney Height	Taller chimney	- Provide better drafts and facilitate dispersal of cremator emissions	- Higher visual intrusion	- Taller chimneys would stand out more prominently against the natural landscape, creating a significant visual intrusion that could detract from the aesthetic and natural character of the surrounding area. The higher the chimney, the more difficult it becomes to conceal it against the natural ridgelines, potentially leading to a visual impact that could be considered unsightly or out of place in a predominantly natural environment.
Design – Chimney Height	Shorter chimney *()**	- Optimised heights to be better screened by natural terrain	- Less efficient dispersal of pollutants but can still meet AQO	- Not applicable.
Cremation Technology	Flat-bed (Subject to future design)	- Proven technically feasible in HK	- Not applicable	- Not Applicable.
Cremation Technology	Free-falling (Subject to future design)	- Proven technically feasible in HK	- Not applicable	- Not Applicable.
Selection of Size of Cremators	All ten large (250kg) cremators	- Not applicable	- Require additional amount of fuel for cremation process	- Larger cremators capable of handling up to 250 kg are less energy-efficient compared to standard cremators with a capacity of 170 kg. They require more fuel per cremation session, leading to higher operational costs and increased energy use. - The use of larger cremators results in greater air pollutant emissions due to the higher fuel requirements. This does not only impact the crematorium's operational sustainability but also contributes to a larger carbon footprint, contradicting the efforts to minimize environmental impacts. - While it is necessary to accommodate deceased individuals of significantly higher weights, such situations are less frequent compared to cases that standard cremators can handle. Employing all large cremators would mean that the facility is less optimized for the majority of cases, resulting in inefficiencies in energy use and operational costs.
Selection of Size of Cremators	Nine standard (170kg) cremators and one larger cremator (250kg) *()**	- Balancing the need to handle heavier bodies while promoting energy efficiency and reducing air pollutant emissions	- Require less amount of fuel for cremation process	- Not Applicable.
Choice of Fuel for Cremators	Ultra-low sulphur diesel (ULSD)	- Need not connect to Towngas network	- Emission of sulphur dioxide (SO₂) - Higher emission of carbon dioxide (CO₂)and carbon monoxide (CO) - Extra exaction required for an underground fuel tank	- Although ULSD is a cleaner version of diesel, its combustion still results in emission of SO₂, an air pollutant known to have adverse health effects. This emission is particularly concerning in urban or populated areas where environmental quality is crucial. - ULSD has a higher carbon intensity compared to Towngas. Its combustion leads to higher emissions of CO₂ and CO, which are greenhouse gases. Increased CO₂ and CO emissions would contribute to global warming and climate change, as well as potential health risks to nearby communities.
Choice of Fuel for Cremators	Towngas *()**	- Negligible emission of SO₂ - Less emission of CO₂and CO - No need to construct underground fuel tank	- Need to connect to Towngas network	- Not Applicable.

2.4 Proposed Development Scheme

2.4.1 The proposed WHS Crematorium comprises a number of elements, which are as follows:

a) Site clearance, site formation and superstructure works including provision of ten new coffin cremators (comprising nine (9) standard cremators and one (1) large cremator with air treatment system);

b) Provision of a full range of ancillary facilities including:

· six (6) service halls;

· office accommodation for FEHD staff and reception area;

· six (6) Eco-joss paper burners;

· mortuary;

· ash storage room;

· pulverization room;

· office accommodation for Electrical and Mechanical Services Department (EMSD) staff;

· EMSD maintenance workshop and spare part store;

· refuse storage chamber;

· passenger lifts and goods lifts;

· public toilets including accessible unisex toilets and universal toilet, as well as baby care room;

· layby for hearses, etc;

c) Control room, equipped with Closed-Circuit Television (CCTV) system;

d) Separate control room inside cremation plant room equipped with CCTV system; and

e) Landscaping.

2.4.2 In order to support the development of the Project, the following works will be required during construction phase:

a) Site clearance, site formation works, slope upgrading and landscaping works within and outside the proposed WHS Crematorium Site (about 2ha) but within the Project Boundary;

b) Demolishment of the existing sand trap (to be replaced by a landscape water feature) and connected ditches;

c) Foundation works for the proposed crematorium; and

d) Superstructure works and miscellaneous works including internal access road, emergency vehicular access, internal fitting, sewerage, drainage and landscaping works within the Project Site

2.4.3 The layout plans of the proposed WHS Crematorium Site at different levels are shown in Figure 2.1. Specific building design parameters are summarised in Table 2.2 below.

Table 2.2 Summary of Conceptual Building Design Layout

Parameters	Units
Number of Buildings	3
Number of Storeys	4
Building Height	+137.560 mPD (Service Halls 1) +138.000 mPD (Service Halls 2) +137.280 mPD (Service Halls 3) +136.600 mPD (Service Halls 4) +136.200 mPD (Service Halls 5 & 6) +125.550 mPD (Crematorium)
Number of Cremators	10 (9 standard cremators and 1 large cremator)
Number of Chimneys ⁽¹⁾	3
Exhaust Stack Release Height ⁽²⁾	Chimney nos. 1 and 2: +141.6 mPD (~28m from cremator plant room at 1/F of crematorium building block) Chimney no. 3: +144.84 mPD (~31m from cremator plant room at 1/F of service hall block)
Notes: (1) Each cremator will have its own individual exhaust stack. For the 9 standard cremators, 4 of their individual stacks will be grouped inside Chimney no.1, the other 4 stacks will be similarly grouped inside Chimney no. 2. The last standard cremator stack and the large cremator exhaust stack will be grouped inside Chimney no. 3. (2) The chimney structures are designed to be several metres higher than the release height of the individual cremator stacks to reduce visual impact.

Cremation System

2.4.4 The proposed cremation facility has 10 cremators, including 9 standard units (170 kg capacity each) and 1 large unit (250 kg capacity), operating normally from 08:30 to 23:00 daily, with occasional extensions that may occur. The facility will utilize Towngas as its fuel, chosen for its environmental advantages such as negligible emission of sulphur dioxide and lower emissions of carbon dioxide and carbon monoxide compared to alternatives. A key feature is the heat recovery system that utilizes the thermal energy from exhaust gases to preheat incoming air, enhancing overall efficiency.

2.4.5 The facility incorporates comprehensive environmental controls. A three-stage heat exchanger cools the flue gases, reducing the potential for dioxin reformation and aiding in energy recovery. Emissions are rigorously monitored by a Continuous Emission Monitoring System (CEMS) that ensures compliance with relevant environmental standards by tracking pollutant levels, temperature, and oxygen content. Additionally, operational parameters and designs are aligned with proven practices from other Towngas-utilizing facilities, ensuring the crematorium meets stringent regulatory guidelines for emission control and operational efficiency. This approach not only ensures environmental compliance but also supports community health and sustainability goals.

Air Pollution Control Systems – Cremators

2.4.6 To mitigate air pollutant emissions from the cremation process, advanced Air Pollution Control (APC) equipment will be installed, of which the specific system will be used will be finalized at detailed design stages. The following various APC technologies have been considered in the EIA report:

· Wet Scrubbing

· Rapid Quenching

· Electrostatic Precipitation and Cyclone Separators

· Flat Bag Filters

· Chemical Neutralization

· Carbon Injection

· De-NOx Systems

2.4.7 Each technology will be selected based on its effectiveness in removing specific pollutants, operational feasibility, and compliance with environmental regulations, ensuring the crematorium operates efficiently while minimizing its environmental impact.

Air Pollution Control Systems – Joss Paper Burners

2.4.8 The Project also includes installation of six eco-friendly joss paper burners, each with a burning capacity of 40 kg/hour, operating daily from 08:30 to 18:00. To ensure environmental compliance, the flue gases produced by these burners will undergo treatment using water scrubbers and electrostatic precipitators, adhering to the EPD’s guidelines on air pollution control for joss paper burning. These measures are designed to significantly mitigate any potential air quality impacts. Through the implementation of advanced flue gas treatment technologies and administrative controls, the Project is expected to maintain minimal environmental impact from its operations.

Sequence of Construction Works

2.4.9 The construction of the Project will commence with site clearance and soil excavation, followed by the installation of pipe or sheet pile walling to support excavation for foundation work. Construction will progress with foundation setting, followed by sequential building of the superstructure, including formwork, rebar placement, and concreting. Once the structural work is complete, installation of building services and interior finishes will finalize the Project. This streamlined approach ensures efficient project execution from groundwork to completion.

2.5 Visual Treatment of the Proposed Development

2.5.1 The Project is located in a vegetated trough area surrounded by slopes on three sides within the Wo Hop Shek Cemetery. In order to avoid extensive excavation works, the proposed crematorium will sit at the bottom of the trough area with ancillary facilities planned largely according to existing topography. The major portion of the crematorium is therefore screened by the surrounding natural terrain with dense vegetation and its visual impact would be minimised.

2.5.2 To balance other environment impacts, the heights of the chimney structure have been optimised to approximately +148.950mPD, which would be largely screened by the natural terrain with higher ridgeline levels. Only the tips of the chimneys could be seen from distant views. Natural materials such as fair-faced concrete and timber pattern materials, together with adequate plantings and greening, will be used to make the building further blend into the surrounding natural environment. Large-sized glass surfaces for the building structure will not be excessively use to reduce the risk of bird collision.

2.6 Project Implementation Programme

2.6.1 The tentative implementation programme for the Project is provided in Table 2.3.

Table 2.3 Tentative Project Implementation Programme

Task	Tentative Timeframe
Commencement of Construction	2026
Completion of Construction	2030
Commissioning Date	2030

3 Summary of Environmental Impacts

3.1 Approach to Environmental Impact Assessment

3.1.1 The EIA process serves as a crucial method of scoping, assessing and reporting the environmental impacts and benefits of the Project. This iterative procedure has run concurrently since the design phase to pinpoint potential environmental consequences of various design options, development alternatives, and establish mitigation measures to integrate into the design, construction and operation of the proposed WHS crematorium. Public concerns have been thoroughly taken into account and integrated where necessary. Mitigation measures have been proposed to prevent certain environmental impacts or reduce and manage them to acceptable levels.

3.2 Air Quality Impact

3.2.1 Potential air quality impacts associated with the construction and operation of the Project have been assessed in accordance with Clause 3.4.4 and Appendix B of the Study Brief and Section 1 of Annex 4 and Annex 12 of EIAO-TM to ensure compliance of the Air Quality Objectives (AQOs) and relevant criteria and guidelines.

3.2.2 During construction phase of the Project, potential air quality impact including dust and particulate matter emissions may arise due to earth-moving, excavation, and vehicular activities. To mitigate the dust impacts, it is proposed to regularly dampen the site, cover all material transports, and strictly adhere to the Air Pollution Control (Construction Dust) Regulations. These measures would effectively control the release of fugitive dust into the environment. With implementation of the above, no adverse air quality impacts are anticipated during construction phase. RSP and FSP monitoring will be conducted during construction phase to ensure that no nearby ASRs will be subject to adverse air quality impact.

3.2.3 The design, the operation and the commissioning of the proposed cremators would comply with the

3.2.3BPM 12/2(2020). During operational phase, emissions from cremators and joss paper burners, including particulate matter (i.e. respirable suspended particulates (RSP) and fine suspended particulates (FSP)), nitrogen dioxide (NO₂), total organic carbon, hydrogen chloride, carbon monoxide, ammonia, mercury and dioxin are of primary concern. However, adverse air quality impacts are not anticipated during operation phase with implementation of advanced emission control technologies such as filters and scrubbers to meet stringent emission standards. Regular maintenance and diligent monitoring will also be carried out to ensure ongoing compliance with environmental regulations. In case of failure of any part of the cremator system, the operation will be suspended, and the failure should be rectified as soon as possible. Emissions from the existing WHS crematorium, the nearby industrial emission as well as vehicular emission from open roads have also been assessed for the operational phase of the Project.

3.2.4 Whilst the proposed cremators would operate during the normal operating hours from 08:30 to 23:00, there may be rare emergency cases where 24-hour continuous operation is required. Therefore, two air quality impact assessments were conducted respectively for the normal operating scenario and emergency scenario. The results for both scenarios indicate that the concentrations at all representative ASRs would comply with the respective Air Quality Objectives (AQOs) and also other international standards. Thus, no adverse air quality impact due to operation of the Project is anticipated.

3.2.5 Ammonia emissions from the cremation process could potentially impact local odour levels. To manage this, operation of the crematorium shall adhere to strict operational practices and emission limits, particularly when using urea or ammonia in de-NOx systems, is essential for effective odour management. The odour impact predicted at the identified ASRs has been found to comply with the relevant assessment criteria for both normal and emergency operating scenarios. Thus, no adverse odour impact due to operation of the Project, i.e. from chimney emission, is anticipated.

3.2.6 The potential human health risks associated with dioxin emissions from the proposed crematorium have also been assessed. The predicted incremental human health risk at the representative ASRs is well below the USEPA’s target acceptable level of 1 x 10^-6. Therefore, no incremental human health risk from the Project is anticipated.

3.2.7 If all the recommended mitigation measures are implemented appropriately, no residual impacts on air quality due to construction and operation of the Project are anticipated.

3.2.8 A summary of the highest predicted cumulative air quality impact at representative ASRs under the normal operation and emergency operation scenarios is shown below in Table 3.1 and Table 3.2.

Table 3.1 Summary of Highest Predicted Concentrations for AQO Pollutants during Operational Phase

Operating Scenarios	Highest Predicted Cumulative Pollutant Concentrations for AQO Pollutants (µg/m³)
	SO₂		RSP		FSP		NO₂			CO
	4^th highest 10-min	4^th highest 24-hr	10^th highest 24-hr	Annual	19^th highest 24-hr	Annual	19^th highest 1-hr	10^th highest 24-hr	Annual	1-hr	8-hr	24-hr
Normal Operating Scenario	28	7	54	21	34	13	78	31	17	549	505	463
Emergency Scenario ^[1]	29	7	54	-	34	-	106	45	-	549	506	464
Prevailing AQO Criteria (μg/m³)	500	50	100	50	50	25	200	-	40	30,000	10,000	-
Proposed AQO Criteria (μg/m³)	500	40	75	30	37.5	15	200	120	40	30,000	10,000	4,000

Note 1: Emergency situations would have impacts to short term pollutant concentrations only due to its infrequent nature.

Table 3.2 Summary of Highest Predicted Concentrations for Other Pollutants during Operational Phase

Operating Scenarios	Highest Predicted Cumulative Pollutant Concentrations for Other Pollutants (µg/m³)
	HCl		Hg		Dioxin (pg/m³)	TOC		Ammonia
	1hr	Annual	1hr	Annual	Annual	1-hr	Annual	1-hr	Annual
Normal Operating Scenario	6.57	0.88	0.0049	0.00079	0.0312	23.86	7.04	8.20	1.91
Emergency Scenario	6.57	-	0.0049	-	-	23.86	-	8.33	-
Assessment Criteria (μg/m³)	2100	9, 20	0.6	0.03, 0.3, 1	40	N/A	N/A	3200	200, 500

Note 1: Emergency situations would have impacts to short term pollutant concentrations only due to its infrequent nature.

3.3 Noise Impact

3.3.1 Noise impact assessment was conducted to evaluate the noise impacts during both the construction and operation phases of the Project. The assessment was carried out in accordance with Clause 3.4.5 of the Study Brief and Annexes 5 and 13 of the EIAO-TM to ensure compliance of relevant standards and guidelines. There are no existing, committed or planned Noise Sensitive Receivers (NSRs) within the 300 m assessment area of the Project Boundary.

3.3.2 The construction noise impact assessment carried out focused on the various construction activities, particularly those involving the use of Powered Mechanical Equipment (PME). The assessment confirmed that with implementation of mitigation measures, including utilization of quieter PME and adherence to good construction practices to minimize noise disturbances, adverse construction noise impact on the representative Noise Sensitive Receivers (NSRs) is not anticipated.

3.3.3 During operation phase, noise impacts arising from road traffic and fixed noise sources such as ventilation systems and cremation equipment were assessed. The assessments confirmed that with the implementation of recommended mitigation measures such as suitable selection of plant equipment, installation of silencer and enclosures, etc., the operation noise levels can be controlled to within the relevant acceptable limits, hence no adverse fixed noise impacts on the surrounding environment is envisaged. In addition, no induced adverse road traffic noise is anticipated since there would not be significant increase in traffic flow of the concerned roads during both normal and festive days (i.e. Ching Ming and Chung Yeung Festivals).

3.3.4 If all the recommended mitigation measures are implemented appropriately, no residual noise impacts due to construction and operation of the Project are anticipated.

3.4 Water Quality Impact

3.4.1 Potential water quality impacts associated with the construction and operation of Project have been assessed in accordance with Clause 3.4.6 and Appendix C of the Study Brief and Annexes 6 and 14 of the EIAO-TM to ensure compliance of relevant standards and guidelines.

3.4.2 Several water sensitive receivers (WSRs) within the 500m Assessment Area have been identified. These include the Water Gathering Ground designated by the Water Supplies Department, the sand trap with retained water within the Project Boundary and perennial/seasonal watercourses on the surrounding hillslopes.

3.4.3 During construction phase, potential water quality impact would arise from the surface runoff and site effluent from construction activities, sewage from workforce and accidental spillage of chemicals. With implementation of recommended mitigation measures, good site practices and adherence to environmental regulations etc., adverse water quality impact arising from construction phase of the Project is not anticipated.

3.4.4 During operation phase, potential water pollution sources include wastewater generated by operation of the crematorium facilities, sewage from visitors and staff and surface runoff generated from the proposed WHS Crematorium Site. All of these may affect the water quality, if not properly controlled. During operation phase, sewage generated from the visitors and workers at the proposed crematorium will be diverted to a new public sewer connected to the existing sewers at Kiu Tau Road and Ming Yin Road, which will be eventually conveyed to Shek Wu Hui Sewage Treatment Works for treatment. It is confirmed, in a separate submission, that the existing sewerage network and the sewage treatment facility have sufficient capacity for treating the sewage generated from the Project. The wastewater generated by operation of the crematorium facilities (joss paper burners) will also be conveyed to public sewer, ultimately to sewage treatment works for treatment. Surface runoff generated during the operation of the Project will be conveyed to the nearby existing government drainage system via peripheral drain, therefore, no water quality impact caused by the surface runoff during the operation phase is anticipated.

3.4.5 If all the recommended mitigation measures are implemented appropriately, no residual impacts on water quality due to construction and operation of the Project are anticipated.

3.5 Waste Management Implications

3.5.1 Waste management implications associated with construction and operation of the Project have been assessed in accordance with Clause 3.4.7 and Appendix D of the Study Brief and the criteria and guidelines stipulated in Annexes 7 and 15 respectively of the EIAO-TM.

3.5.2 The waste management implications for the proposed WHS Crematorium development have been assessed in the EIA report focussing on the types of waste likely to be generated during both the construction and operation phases. The quantity, quality and timing of the wastes arising as a result of the construction and operation activities of the Project have been estimated.

3.5.3 Waste is anticipated to be generated by construction activities such as site clearance and tree removal, site formation and excavation, superstructure works of the and proposed crematorium and its ancillary facilities, as well as landscaping and slope works. The types of waste associated with these construction activities primarily consist of C&D materials, yard, chemical waste and general refuse.

3.5.4 The operational activities of the proposed crematorium will contribute waste types, including bottom ash generated by cremators during the combustion process, fly ash generated from the Air Pollution Control (APC) equipment, chemical waste generated from plant, equipment and machinery maintenance and servicing; and general refuse generated by the visitors and staff during daily operation.

3.5.5 Mitigation measures have been recommended based on the waste management hierarchy principles, i.e. avoidance, minimisation, recycling/ reuse, treatment and disposal. With proper implementation of the recommended mitigation measures, impacts on the environment arising from the waste handling and disposal associated with the proposed WHS Crematorium during construction and operation phases are not anticipated.

3.5.6 If all the recommended mitigation measures are implemented appropriately, no residual impacts on waste generation due to construction and operation of the Project are anticipated.

3.6 Ecological Impact

3.6.1 An ecological impact assessment has been undertaken for the Project in accordance with Clause 3.4.8 and Appendix E of the Study Brief, and Annex 8 and Annex 16 of the EIAO-TM. The baseline ecological profile within the 500m Assessment Area has been established through a comprehensive literature review and a six-month ecological survey that covered both the wet and dry seasons. The impact assessment made reference to the best available information during the time of reporting, and the source, nature and significance of the potential ecological impacts associated with the Project were identified and evaluated.

3.6.2 It is concluded that impact from direct habitat loss or construction disturbance to terrestrial habitats and wildlife outside the Project Boundary is considered as Low due to the ecological value, size and fragmented nature of habitats within the Project Boundary, as well as its trough location and hence predicted disturbance is localised in nature. Nonetheless, direct loss of floral/ faunal of conservation importance due to the site clearance of the Project would have a Low to Moderate impact, whereas the impact from potential indirect disturbance to the natural watercourses downstream of the Project Boundary from handling untreated surface runoff of the crematorium, or deterioration in habitat quality nearby from light glare/ sky glow emitted by artificial lighting, may range from Low to Moderate to High if unmanaged.

3.6.3 Corresponding mitigation measures have been recommended for both construction and operation phases, which include avoidance measures for any direct loss of floral/ faunal species of conservation importance, avoidance/ minimization measures for the potential indirect disturbance to natural watercourses and associated wildlife, as well as minimization measures for potential light glare and sky glow. Furthermore, good site practices from an ecological perspective have also been recommended to avoid and minimize the potential disturbance to the wildlife and habitat nearby.

3.6.4 A baseline vegetation survey will be conducted before site clearance to update the presence and location of flora species of conservation importance, including Incense Tree. Suitability for transplanting affected plants will be assessed and ecological monitoring will be implemented for preserved or transplanted flora species with proposed monitoring details in the "Preservation and Transplanting Proposal" covering the construction period and post-transplanting period if applicable.

3.6.5 A checking for the presence of Lesser Spiny Frog and Short-legged Toad and other fauna species of conservation importance before site clearance will be conducted. If found, an "Animal Capture Survey and Relocation Plan" will be prepared and submitted to the Authority for approval; detailed translocation method and post-translocation monitoring will be determined and discussed in the plan, if applicable.

3.6.6 In conclusion, with effective implementation of the proposed ecological mitigation measures, the Project would not have residual ecological impact during its construction and operation phases.

4 Environmental Monitoring and Audit

4.1.1 An Environmental Monitoring and Audit (EM&A) programme has been formulated, with details presented in the separate EM&A Manual. The EM&A programme provides management actions to check the effectiveness of the recommended mitigation measures and compliance with relevant criteria, thereby ensuring the environmental acceptability of the Project during construction and operation phases.

4.1.2 Environmental monitoring is recommended for air quality and ecology (if applicable) to ensure compliance with relevant requirements. Site audit is recommended to be undertaken regularly during the construction phase to ensure that the recommended environmental protection and pollution control mitigation measures are properly implemented.

5 Conclusion

5.1.1 The EIA Study has examined the possible environmental impacts stemming from both the construction and operation phases of the Project, in accordance with the Study Brief (ESB-362/2023) and the EIAO-TM. Based on the assessments carried out, the Project is expected to meet the relevant environmental standards with the implementation of the recommended mitigation measures during both the construction and operation phases.