Yau Tong Bay Development - Engineering Feasibility Study for the Comprehensive
Development at Yau Tong Bay
Application for Approval of an EIA Report Submitted on 29 August 2000
(Application No. EIA-048/2000)
Reasons for the EIA Report Submitted on 29 August 2000 Not Meeting the Requirements of the EIA Study Brief [ref. No. ESB-0028/1999] (Study Brief) and the Technical Memorandum on the EIA Process (TM)
As explained in the letter attached to this Appendix A, some of the reasons given below relate to another EIA Report submitted by the same applicant on 25 July 2000 for approval under section 6(2) of the EIA Ordinance (Application No. EIA-046/2000).
1. Some private lots with operations which are environmentally incompatible with residential uses might remain for a very long period of time. The industrial or shipyard operations [YTMLs 73 & 74 (Agincourt Industrial Building); YTMLs 1-5 (Tai Yuen Shipyards) and YTMLs 25-27 (Other 3 shipyards)] might continue their operations as shipyards or sawmills or timberyards, which will cause serious environmental nuisance in terms of noise and dust emissions. This Schedule 3 EIA Report has ignored the very severe potential industrial/residential (I/R) interface problems that would be extremely difficult to mitigate. Similar severe 'I/R' interface problems were experienced by the former Shipyards at North Tsing Yi close to the Cheung On Estate; and the Hong Kong Cement Plant adjacent to the Greenfield Garden in Tsing Yi. For both cases, there were no practical mitigating solutions to eradicate the environmental problems except for ultimate relocation of the polluting sources. To allow the co-existence of these polluting industrial uses with the future residents of the Yau Tong Bay Comprehensive Development is in fact creating multiple industrial/residential interface problems within a Comprehensive Development Area that might create potentially serious environmental concerns, and is therefore considered unacceptable on environmental grounds. This would likely create environmental incompatibility. S.1.4, S.2.1, S.3.5.3 and S.3.6.1 of the Study Brief and S.4.3.3, S.4.4.2 & S.4.4.3 of the TM have not been met.
2. According to the construction programme in Figure 2.2 of the EIA Report, the construction period for the superstructures is scheduled from October 2002 to March 2015. With reference to the construction programme in Appendix 2A of another EIA Report entitled "Yau Tong Bay Development - Reclamation of Yau Tong Bay" submitted on 25 July 2000 under section 6(2) of the EIA Ordinance, the construction period for the Phases 1 and 2 of the reclamation works is scheduled from July 2001 to April 2005, and the programme for the Phase 3 reclamation is missing in that EIA Report. In the context of what are recorded in these two EIA Reports, the construction period of the foundation/superstructure works will appear to overlap with that of the reclamation works for at least 2? years (i.e. from October 2002 to April 2005). The overlapping period may even be longer than 2? years if the Phase 3 reclamation is to be taken into consideration. However, both EIA Reports, including this Schedule 3 EIA Report, fail to identify, predict and evaluate the overall cumulative impacts of all the construction activities that will take place during the above overlapping period.
In addition, the cumulative construction impacts have to take into account other concurrent construction activities (existing, planned and committed developments) in the vicinity of the project, such as the Yau Tong Estate redevelopment, the East Harbour Crossing Housing Estates and the Western Coast Road (WCR). Dependent on the timing of the various population intakes in the respective housing sites/schools, a maximum population of approaching 50,000 people could be adversely affected by the cumulative impacts of such works. Again, both EIA Reports, including this Schedule 3 EIA Report, fail to make reasonable attempts to predict and evaluate the overall cumulative impacts due to other concurrent major construction activities. S.1.4, S.2.1, S.3.4 & S.3.6 of the Study Brief and S.4.3.3 & S.4.4.2 of the TM have not been met.
3. This EIA Report proposed a comprehensive development that comprises high-rise residential towers with building height ranging from about 125m to 160m, and with two commercial towers with building height reaching to about 200m. These high-rise buildings will well exceed the height band of 125m as recommended under the Central and East Kowloon Development Statement and in breach of the ridgeline for the Kowloon hills. As illustrated by the photomontages in Figures 8.13 to 8.16 of the EIA Report, the adverse visual impact of the Yau Tong Bay Comprehensive Development on the visually sensitive receivers at the surroundings such as Hong Pak Court and the committed/planned developments at Cha Kwo Ling and Yau Tong Industrial Area will be severe and irreversible. This EIA Report fails to provide alternative designs to reduce the visual impacts of the project. S.3.10.5 of the Study Brief & Annex 10 S.1.1 of the TM have not been met.
4. Apart from the above, there are other omissions or deficiencies in the EIA Report as described below.
(a) Outstanding Landscape and Visual Impact Assessment
We note the following omissions and errors in the visual and landscape impact assessment. S.3.10.4 of the Study Brief and Annex 10 S.1.1 of the TM have not been met:
(i) The assessment on the visual impacts of the proposed development against the representative groups of visually sensitive receivers (VSRs) is incomprehensive. Some VSRs on the committed and planned developments at Yau Tong Industrial Areas and Cha Kwo Ling development have not been adequately assessed.
(ii) The assessment by graphic illustrations of the visual impacts on the existing VSRs is inadequate, and the actual visual impacts on the public and private developments fronting the proposed development are under-estimated.
(iii) There is no alternative design as mitigation measures against the breach of ridgeline of Kowloon hills.
(iv) There is no information relating to the funding, implementation, management and maintenance of the proposed landscape and visual mitigation works. In addition, mitigation measures as recommended in the landscape and visual impact assessment have not been included in the Implementation Schedule. For example, the mitigation measures at the operation phase are missing.
(b) Traffic Noise Impact on the Residential Blocks
(i) The traffic noise impacts from Cha Kwo Ling Road on residential blocks 11, 25 and 43 will exceed the 70dB(A) traffic noise criterion, but there is no consideration in the EIA Report to further setback the blocks from Cha Kwo Ling Road or to provide alternative uses to avoid the traffic noise impacts. In accordance with TM Annex 13 S.6.1, the direct mitigation measures including setback should be exhausted prior to consider indirect technical remedies. S.3.6.1 of the Study Brief and Annex 13 S.6.1 of the TM have not been met.
(ii) The residential blocks along Ko Fai Road will also exceed the 70dB(A) traffic noise criterion. The recommended 2m high podium edge noise barrier for Tunnel Option of the WCR (without Ko Fai Road connection) is inadequate, as 5m high podium edge noise barrier is recommended at the same location in the WCR (coastal option). S.3.6.1 of the Study Brief and Annex 13 S.6.1 of the TM has not been met.
(c) Data & Methods in the Air Quality Impact Assessment
We note the following omissions and errors in the air quality impact assessment. S.3.5.3 of the Study Brief and S.4.4.2 of the TM have not been met:
(i) The EIA Report has studied two WCR tunnel options (with and without Ko Fai Road connection), but there is only one set of traffic emission impact assessment result provided in the report. Hence, the assessment is incomplete. In addition, some key assumptions are missing in this traffic emission impact assessment, e.g. location of exhaust of the tunnel of the WCR.
(ii) The height of the volume sources which is used to simulate the portal emission from the Eastern Harbour Crossing should be 5.8m high (vertical dimension of the cross section of the portal) instead of 10m.
(iii) Volume sources have been used in simulating the impact of emission from the vehicles in the toll plaza region. As the emissions from idling vehicles is close to the ground level (about 0.5m above ground) and there is no initial plume dispersion due to mechanical turbulence generated by the vehicles, area sources should be used instead.
(iv) S.3.8.13 of the report indicates that only two categories of the vehicle types have been considered in the assessment. However, according to Table 3.5 and Appendix 3C, there are other vehicle types which have also been included in estimating the portal and vent-shaft emissions from tunnels.
(v) There are discrepancies in the traffic flow figures for the traffic emission and traffic noise impact assessments. In the traffic emission impact assessment, the traffic flow and vehicle composition for all roads remain the same for both tunnel options (with and without the connection to Ko Fai Road) except for Cha Kwo Ling Road. However, in the traffic noise impact assessment (Tables 4.10 and 4.11), the traffic flows on Ko Fai Road are different from the two tunnel options.
(d) Impacts on the Sewerage System
(i) The EIA Report has tried to cater for the shortfall of the existing East Kowloon sewerage capacity due to the comprehensive residential development. However, a number of the important assumptions in the sewerage impact assessment are either too optimistic or outdated. These include the timely implementation of SSDS Stage III/IV, and the upgrading of the Kwun Tong Preliminary Treatment Works and the Yau Tong Sewerage Pumping Station. In fact, according to the latest review studies (including the Interim Report (December 1999) of the Review of Central and East Kowloon Sewerage Master Plans), some of the works are uncertain at this stage. The EIA Report has not catered for the worst case scenario that all the above works may be delayed. Hence, the size of the temporary sewerage holding tank may need to be increased, and the location, the housing layout plan may need to be adjusted for its accommodation. If the housing layout plan is amended, the traffic noise and traffic emission impact assessments will also need to be revised. S.3.8.2 of the Study Brief and Annex 14 S.6.5 of the TM have not been met.
(ii) The population figures adopted in the sewerage impact assessment in the EIA Report are under-estimated. The project proponent could make reference to the population data adopted in the Study entitled "Review of Central and East Kowloon Sewerage Master Plans". Annex 14 S.6.5 of the TM has not been met.
(e) Summary of Key Environmental Outcomes
(i) The EIA has not summarized the key environmental outcomes. S.3.11 of the Study Brief has not been met.
(f) Electronic Copies of the EIA Report
(i) The electronic copies of the EIA Report and the Executive Summary have not been submitted. S.6.3 and S.6.4 of the Study Brief have not been met.