9.1       Introduction

9.1.1        Under the EIAO Schedule 2, the proposed Joint User Complex and Wholesale Fish Market at Area 44 Tuen Mun is a Designated Project. An EIA was conducted with respect to the Study Brief issued by the EPD. Environmental concerns associated with the construction and operation of the proposed development were addressed. Mitigation measures were proposed to alleviate the potential environmental impacts on nearby sensitive receivers and reduce them to acceptable levels in accordance with relevant environmental guidelines, regulations and plans.


9.2       Air Quality

Construction Phase

9.2.1        The subject site is an existing vacant flat area. As no extensive excavation will be carried out at the site and only typical construction site activities will be involved, the dust impact on the surrounding air sensitive users will be minimal. With the implementation of suitable mitigation measures, construction activities will not result in unacceptable environmental impact. The potential air quality impact arising from the construction of the proposed WFM has been assessed and found to be within acceptable levels with the implementation of dust suppression measures. Good site management in accordance with the Dust Control Requirements under the Air Pollution Control (Construction Dust) Regulation will be performed and supervised to ensure that the mitigation measures are implemented effectively. Construction works will be closely monitored to avoid smoke emissions from improperly maintained powered mechanical equipment.

Operational Phase

9.2.2        For the operational phase air quality impact, the assessment has considered odour from the fish market and RCP operations, emissions from additional lorries using the area and emissions from fishing vessels approaching or leaving the market as potential sources of impact on air quality. These sources have been assessed using direct measurements (e.g. odour samples taken at the existing CPFM), where necessary, and air quality prediction models adopting conservative assumptions to ensure that all potential impacts are properly addressed and received necessary mitigation.

9.2.3        Odour from market operations during the peak hours (from 3:00am to 6:30am) has been assessed for the worst case scenario over a year. The predicted odour concentrations at most air sensitive receivers within the study area (i.e. within 500m of the site boundary) are well below the acceptable criteria and would unlikely to cause a nuisance.

9.2.4        Mitigation measures have been proposed to ensure that nearby sensitive receivers will not be subject to unacceptable residual odour impact as a result of market operations. These measures include :

-          full enclosure to lorry-parking and WFM areas facing the nearby sensitive receivers

-          provision of a mechanical ventilation system to extract odour from inside the premises and discharge at the seaside

-          fresh air inlets to be located on the podium to ensure fresh air intake to the mechanical ventilation system

-          no on-street parking by providing adequate parking within the building

-          implementation of a management plan to ensure and monitor good handling and cleansing practices at the market, including suitable containment and daily removal of all organic waste and regular maintenance of equipment.

-          good design with easy clean detailing and use of impervious materials to avoid build up of odour from organic material carried in washing water.


9.2.5        The WFM management will pay particular attention to the specified mitigation measures for odour reduction and to any complaints that arise from nearby receivers.  During the initial 12 months of operations regular odour patrols will be carried out to monitor and verify if the operation of the WFM would cause any odour nuisance to the nearby sensitive receivers. In the event that such monitoring shows a distinct incidence of unpleasant odour at any receiver that is confirmed to be attributable to the operations of the WFM there is provision in the building design to incorporate a scrubber system into the ventilation system to remove odour before it is discharged outside the WFM complex.

9.2.6        Deodourising systems will be incorporated in the designs of the RCP, Marine RCP and public toilet to mitigate possible impacts from these sources.

9.2.7        No unacceptable impacts are expected to arise from offsite marine traffic or vehicular emissions and mitigation measures are not necessary for these potential impact sources.

9.2.8        In summary, the construction and operation of the complex should not lead to unacceptable air quality impact at any of the identified air sensitive receivers provided that the recommended mitigation measures are adopted.


9.3       Noise Impact

            Construction Phase

9.3.1        The construction of the proposed WFM complex is anticipated to last for 26 months (including 9 months piling) and standard construction equipment will be used on site. The potential construction noise impact on the nearby sensitive receivers during the foundation and superstructure phases has been evaluated. The assessment demonstrates that with appropriate mitigation measures, such as using quiet powered mechanical equipment, the construction noise levels at the nearby sensitive receivers are within the acceptable noise limit as stipulated in TMEIA. Practical noise mitigation measures such as scheduling of works, use of movable noise screens and good site management practices are recommended to further alleviate the potential construction noise impact.

Operational Phase

9.3.2        The assessment has identified fixed noise from market operations, traffic noise from additional lorries using the area and marine traffic noise from fishing vessels approaching or leaving the market as potential sources of operational noise impact. These sources have been assessed using direct measurements (noise survey taken at the exiting fish market), where necessary, and noise prediction models adopting conservative assumptions to ensure that all potential impacts are properly addressed and received necessary mitigation.

9.3.3        Sources of fixed noise arising from the market operations and building services plant including that from vessels berthed at the waterfront and lorries loading or waiting to load fish will not cause unacceptable noise impact on any identified sensitive receivers after the recommended mitigation measures are implemented.

9.3.4        Mitigation measures to minimize the noise impacts from the operation of the WFM have been integrated in the building. These measures include :

-          full enclosure to lorry parking and WFM operations  facing nearby sensitive receivers,

-          construction of a projecting 5-meter wide and 90m long canopy to the unloading area of the WFM along the waterfront,

-          acoustic louvres and silencers for mechanical ventilation system and other building services plant,

-          provision of sufficient parking spaces inside the premises to avoid on-street parking/queuing of lorries

-          implementation of a management plan to ensure and monitor good practices for lorry and vessel management and schedule regular maintenance of equipment.


9.3.5        Traffic noise from lorries using the market is not expected to cause unacceptable impact on nearby sensitive receivers in view of the limited additional traffic (up to 40 lorries) involved. Nevertheless, to minimize the potential off-site traffic noise nuisance that may be caused to nearby sensitive receivers, the WFM access junction will be designed to allow only entrance to or exit  from the WFM complex  to the northern section of Wu Shan Road.

9.3.6        Marine traffic noise from the engines of vessels approaching or leaving the market is not expected to cause potential nuisance to any of the sensitive receivers close to the market irrespective of the route they take. Since the operation of the WFM complex  will not increase vessel traffic within the typhoon shelter, it is unlikely that the associated marine traffic noise impact will be greater than at present.

9.3.7        Good management practices will be adopted throughout the operation of the WFM in order to further minimize the potential noise nuisance :

-          assistance will be sought from WFM users and vessel operators to prohibit the use of loudhailer and reduce horn tooting along the seafront

-          vessel operators will be requested to avoid horning except in emergency and to use other means such as phones to notify their presence

-          vessel operators will be encouraged to continue to use the eastern entrance of the typhoon shelter

-          vessel operators will be encouraged to use silencers at fishing vessels’ exhaust

-          practical and safe movement within the harbour will be monitored and maintained, and where possible minimize noise impact to nearby residents


9.3.8        In summary, the construction and operation of the WFM complex will not lead to unacceptable noise impact at any of the identified noise sensitive receivers provided that the recommended mitigation measures are adopted.


9.4             Water Quality

            Construction Phase

9.4.1        During the construction period, the water pollution sources will include piling works, wheel washing, surface runoff and occasional spillage of oil from equipment. The surface runoff generated will mainly be laden with silt and mud and appropriate silt traps will be constructed to avoid water quality impact on the water body.  Chemicals will be will be handled in proper manner in accordance with the statutory requirements and guidance notes. Wastewater and surface runoff from the construction site should be collected and treated appropriately before discharge into storm drains. The required effluent discharge standards and monitoring requirements as stipulated in Water Discharge License will be complied with throughout the construction period.

Operational Phase

9.4.2        Major water pollution sources during the operation of the WFM Complex are cleansing of WFM and refuse collection points and sewage from toilets. The wastewater will contain suspended solids and organic matters. As the site is located in urban area, all the wastewater and foul discharge generated from the WFM Complex will be directed to the foul sewer, whereas uncontaminated rain water will be directed to the surface water system or directly into the sea, whichever is appropriate.


9.5      Waste Management

9.5.1        The general approach of waste management is prioritised as elimination, reduction, reuse, treatment and then disposal of waste. The handling of waste will be conducted in accordance with relevant ordinances, regulations and guidelines to ensure that no environmental nuisance is caused.

Construction Phase

9.5.2        No special waste will be generated during the construction period. The major construction wastes include excavated soil, spent concrete, wooden board and steel; and solid waste such as garbage, plywood and scrap metal. A Waste Management Plan (WMP), to be approved by the Architect, will be required in the building contract in accordance with the Works Bureau Technical Circular No. 29/2000 to set out the disposal strategy and waste management practice to be implemented by the Contractor during construction.

Operational Phase

9.5.3        Market operations will generate daily waste including broken polyfoam boxes, and small amounts of other plastic debris and dead fish. Reusable containers including polyfoam boxes will be used for fish rather than one-use containers. Recycling of material from broken polyfoam boxes will be arranged through a specialist contractor. After cleansing of the market the small amount of dead fish that remains will be sealed in collection bags and removed to the RCP in sealed containers within two hours of completion of auction activities.

9.5.4        Municipal solid waste generated from the community hall, offices and other possible community uses will be segregated. Reuse of materials will be practiced as much as possible within the subject development. Any recyclable and reusable materials will be collected and sent to waste collectors for regeneration.

9.5.5        A management committee will be established to oversee the management and smooth running of the Complex.  The committee will draw up and implement a waste management plan to identify appropriate segregation and disposal of all waste and to check and maintain tidy and hygiene conditions for the Complex at all times. The committee will be responsible for regular assessment and updating of the management plan as necessary.


9.6      Hazard to Life

9.6.1        The location of the WFM Complex is such that about one-third of it would fall within the consultation zone of the LPG installation existing in Area 44 Tuen Mun. The risk assessment, through the use of hazard identification, identified a number of failure scenarios associated with the operation of the LPG installation. The assessment results demonstrate that there is no unacceptable risk to the population of the area.

9.6.2        The following mitigation measures are proposed to reduce the risk to minimal:

-          Presence of a “crane free zone” to reduce the risk of tank damage due to crane operations during construction.

-          Before excavation work is undertaken, the gas company will be contacted to obtain information on all gas pipes in the vicinity of the site. Suitable pipe locating devices and hand dug trial holes will be used to locate and confirm position of underground pipes. All workers will be given sufficient guidance about working in the vicinity of pipelines. Excavation will be carried out with due care following any advice given by the Gas Authority or Gas Company.

-          Presence of a manually operated warning siren to instruct people to take shelter timely in case of emergency and thus reduces the risk to lives.

-          Arrangement will be made with ESSO to avoid LPG delivery during the hours when the spectator stand is fully occupied on the day of the Dragon Boat Festival.

-          The final design of the WFM complex will minimize pedestrian access to the area of podium within the 150m consultation zone of the LPG installation by concentrating planting areas within this zone of the podium where possible.


9.7             Conclusion

9.7.1        The potential environmental impacts due to the construction and operation of the proposed WFM Complex have been assessed with respect to the environmental aspects including air quality, noise, water quality, waste management and hazard to life. With the implementation of suitable mitigation measures and EM&A programme, the construction and operation of the WFM Complex will have no adverse impact on the environment.

9.7.2        Reprovisioning of fish market activities to the new purpose built WFM Complex in Area 44 will allow the closure and removal of the old and inadequate temporary CPFM at Area 27, Tuen Mun. This will improve the environmental conditions in the vicinity of Area 27 with the environmental nuisance caused by the operation of the existing temporary CPFM eliminated and bring obvious environmental benefits to nearby sensitive receivers.