10

10. LANDSCAPE AND VISUAL IMPACT ASSESSMENT

10.1 Introduction

10.1.1 This section presents an assessment on Landscape and Visual Impacts arising from the construction and operation stage of the proposed secondary drainage channel KT13 of Yuen Long, Kam Tin, Ngau Tam Mei & Tin Shui Wai Drainage Improvement, Stage 1 (the Project) in accordance with the Environmental Impact Assessment Ordinance (Cap.499).

10.1.2 The assessment includes:

· A listing of the relevant environmental legislation and guidelines;

· A description of the assessment methodology;

· A definition of the scope and contents of the study;

· A review of the relevant planning and development control framework;

· A review of comments on landscape and visual issues received during previous consultation with the public and/or advisory bodies and how these have been addressed in the design;

· A baseline study providing a comprehensive and accurate description of the baseline landscape and visual character;

· Recommendation of appropriate mitigation measures and associated implementation programmes;

· Identification of the potential landscape and visual impacts and prediction of their magnitude and potential significance, before and after the mitigation measures; and

· An assessment of the acceptability or otherwise of the predicted residual impacts, according to the five criteria set out in Annex 10 of the EIAO-TM.

10.1.3 All potential impacts and proposed mitigation measures are clearly mapped in colour and illustrated with clear annotation and cross-referencing between text, tables and illustrations. Colour photographs showing baseline conditions, and photomontages supporting conclusions are provided and the locations of all viewpoints are clearly mapped. Photomontages at representative locations provide comparison between existing views; proposals on day 1 after completion without mitigation; on day 1 after mitigation, and in year 10 after mitigation.

10.2 Environmental Legislation and Guidelines

10.2.1 The following legislation, standards and guidelines are applicable to the evaluation of landscape and visual impacts associated with the construction and operation of the project:

· Environmental Impact Assessment Ordinance (Cap.499.S.16) and the Technical Memorandum on EIA Process (EIAO TM), particularly Annexes 3, 11, 10, 18, 20 and 21;

· EIAO Guidance Note 8/2002;

· DSDTC No. 2/2004 Protection of Natural Rivers and Streams from Adverse Impacts Arising from Construction Works;

· Draft Kam Tin (South) Outline Zoning Plan No. S/YL-KTS/9;

· Hong Kong Planning Standards and Guidelines (Chapter 10);

· WBTC No. 7/2002 – Tree Planting in Public Works;

· WBTC No. 14/2002 – Management and Maintenance of Natural Vegetation and Landscape Works, and Tree Preservation;

· ETWBTC No. 2/2004 – Maintenance of Vegetation and Hard Landscape Features;

· ETWBTC No. 29/2004 - Registration of Old and Valuable Trees, and Guidelines for their Preservation.

· Forests and Countryside Ordinance (Cap 96) and its subsidiary legislations;

· Animals and Plants (Protection of Endangered Species) Ordinance (Cap. 187);

· Land Administration Office Instruction (LAOI) Section D-12 - Tree Preservation.

10.3 Assessment Methodology

10.3.1 Landscape and visual impacts have been assessed separately for the construction and operational phases.

10.3.2 The assessment of landscape impacts has involved the following procedures.

· Identification of the baseline landscape resources (physical and cultural) and landscape characters found within the study area. This is achieved by site visit and desktop study of topographical maps, information databases and photographs.

· Assessment of the degree of sensitivity to change of the landscape resources/characters. This is influenced by a number of factors including:

o quality and maturity of landscape resources/characters;

o rarity of landscape resources/characters, whether it is considered to be of local, regional, national or global importance;

o ability of the landscape resources/characters to accommodate changes; and

o whether there are any statutory or regulatory limitations/requirements relating to the landscape resources/characters.

The sensitivity of each landscape resource and character is classified as follows:

High:	Important landscape resources/characters of particularly distinctive character or high importance, sensitive to relatively small change.
Medium:	Landscape resources/characters of moderately valued landscape characteristics reasonably tolerant to change.
Low:	Landscape resources/characters of low landscape value and highly tolerant to change.

· Identification of potential sources of landscape impacts. These are the various elements of the construction works and operational procedures that would generate landscape impacts.

· Identification of the magnitude of landscape impacts. The magnitude of the impact (or magnitude of change) depends on a number of factors including:

o scale of development;

o physical extent of the impact;

o compatibility of the project with the surrounding landscape;

o duration of impacts, i.e. whether it is temporary (short, medium or long term) under construction and operation phases; and

o potentially reversible, or permanent and irreversible.

The magnitude of landscape impacts is classified as follows:

Large:	The landscape resources/characters would suffer a major change.
Intermediate:	The landscape resources/characters would suffer a moderate change.
Small:	The landscape resources/characters would suffer slight or barely perceptible changes.
Negligible:	The landscape resources/characters would suffer no discernible change.

· Identification of potential landscape mitigation measures. These may take the form of adopting alternative designs or revisions to the basic engineering and architectural design to prevent and/or minimise adverse impacts; remedial measures such as colour and textural treatment of engineering and building features; and compensatory measures such as the implementation of landscape design measures (e.g. tree planting, creation of new open space etc) to compensate for unavoidable adverse impacts and to attempt to generate potentially beneficial long term impacts. A programme for the mitigation measures is provided. The agencies responsible for the funding, implementation, management and maintenance of the mitigation measures are identified.

· Prediction of the significance of landscape impacts before and after the implementation of the mitigation measures. By synthesising the magnitude of the various impacts and the sensitivity of the various landscape resources/characters, it is possible to identify a series of thresholds to be used as a basis for the categorization of the degree of significance of the impacts in a logical, well-reasoned and consistent fashion. Table 10.1 shows the rationale for dividing the degree of significance into four thresholds, namely insubstantial, slight, moderate, and substantial, depending on the combination of a negligible-small-intermediate-large magnitude of impact and a low-medium-high degree of sensitivity of landscape resource/character.

Table 10.1

Relationship between Receptor Sensitivity and Impact Magnitude in Defining Impact Significance

Magnitude of Impact (Change)		Low	Medium	High
	Large	Moderate	Moderate / Substantial	Substantial
	Intermediate	Slight / Moderate	Moderate	Moderate / Substantial
	Small	Insubstantial / Slight	Slight / Moderate	Moderate
	Negligible	Insubstantial	Insubstantial	Insubstantial
		Receptor Sensitivity (of Landscape Resources/Characters or VSRs)

· Prediction of Acceptability of Impacts. An overall assessment of the acceptability, or otherwise, of the impacts according to the five criteria set out in Annex 10 of the EIAOTM.

10.3.3 The assessment of visual impacts has involved the following procedures.

· Identification of the Zones of Visual Influence during the construction and operational phases of the project. This is achieved by site visit and desktop study of topographic maps and photographs, and preparation of cross-sections to determine visibility of the project from various locations.

· Identification of the Visually Sensitive Receivers (VSRs) within the ZVIs at construction and operational phases. These are the people who would reside within, work within, play within, or travel through, the ZVIs.

· Assessment of the degree of sensitivity to change of the VSRs. Factors considered include:

o the type of VSRs, which is classified according to whether the person is at home, at work, at play, or travelling. Those who view the impact from their homes are considered to be highly sensitive as the attractiveness or otherwise of the outlook from their home will have a substantial effect on their perception of the quality and acceptability of their home environment and their general quality of life. Those who view the impact from their workplace are considered to be only moderately sensitive as the attractiveness or otherwise of the outlook will have a less important, although still material, effect on their perception of their quality of life. The degree to which this applies depends on whether the workplace is industrial, retail or commercial. Those who view the impact whilst taking part in an outdoor leisure activity may display varying sensitivity depending on the type of leisure activity. Those who view the impact whilst travelling on a public thoroughfare will also display varying sensitivity depending on the speed of travel.

o other factors which are considered (as required by EIAO GN 8/2002) include the value and quality of existing views, the availability and amenity of alternative views, estimated number of receiver population, the duration or frequency of view, and the degree of visibility.

The sensitivity of VSRs is classified as follows:

High:	The VSR is highly sensitive to any change in their viewing experience.
Medium:	The VSR is moderately sensitive to any change in their viewing experience.
Low:	The VSR is only slightly sensitive to any change in their viewing experience.

· Identification of potential sources of visual impacts. These are the various elements of the construction works and operational procedures that would generate visual impacts.

· Assessment of the potential magnitude of visual impacts. Factors considered include:

o scale of development;

o compatibility of the project with the visual context;

o duration of the impact under construction and operation phases;

o reversibility of the impact;

o distance of the source of impact from the viewer;

o degree of visibility of the impact and degree of which the impact dominates the field of vision of the viewer.

The magnitude of visual impacts is classified as follows:

Large:	The VSRs would suffer a major change in their viewing experience.
Intermediate:	The VSRs would suffer a moderate in their viewing experience.
Small:	The VSRs would suffer a small change in their viewing experience.
Negligible:	The VSRs would suffer no discernible change in their viewing experience.

· Identification of potential visual mitigation measures. These may take the form of adopting alternative designs or revisions to the basic engineering and architectural design to prevent and/or minimise adverse impacts; remedial measures such as colour and textural treatment of building features; and tree planting to screen the proposed engineering structures or building. A programme for the mitigation measures is provided. The agencies responsible for the implementation, management and maintenance of the mitigation measures are identified.

· Prediction of the significance of visual impacts before and after the implementation of the mitigation measures. By synthesising the magnitude of the various visual impacts and the sensitivity of the VSRs, and the numbers of VSRs that are affected, it is possible to categorise the degree of significance of the impacts in a logical, well-reasoned and consistent fashion. Table 10.1 shows the rationale for dividing the degree of significance into four thresholds, namely, insubstantial, slight, moderate and substantial, depending on the combination of a negligible-small-intermediate-large magnitude of impact and a low-medium-high degree of sensitivity of VSRs.

The significance of visual impacts is categorised as follows:

Substantial:	Adverse / beneficial impact where the proposal would cause significant deterioration or improvement in existing visual quality.
Moderate:	Adverse / beneficial impact where the proposal would cause a noticeable deterioration or improvement in existing visual quality.
Slight:	Adverse / beneficial impact where the proposal would cause a barely perceptible deterioration or improvement in existing visual quality.
Insubstantial:	No discernible change in the existing visual quality.

· Prediction of Acceptability of Impacts. An overall assessment of the acceptability, or otherwise, of the impacts according to the five criteria set out in Annex 10 of the EIAOTM.

10.4 Scope and Content of the Study

10.4.1 The nature and scope of the Project is described in Section 2 of this Report. In accordance with the Study Brief, this section considers and assesses the landscape and visual impacts during construction and operational phases associated with the secondary drainage channel KT13 identified as a Designated Project (DP) in Section 1.

10.4.2 No cumulative landscape and visual impacts of significance from the concurrent drainage projects are identified in Section 2.6 and will not be covered in this EIA. Two nearby secondary drainage channels KT14 and KT15 are approximately 650m and 1300m separated from KT13 respectively. As such, no cumulative visual impact is envisaged.

Limits of the Study Area

10.4.3 The limit of the landscape impact assessment is not specified in the Study Brief. However, it is recommended that the limit for landscape impact assessment is 100m (as illustrated in Drawing no. LR-001) beyond the limit of the works limit because based on the desk top study and site visit, there will be no change in the landscape resources beyond 100m away from the works areas.

10.4.4 The limits of the visual impact assessment are the zones of visual influence (ZVIs) of the works during the construction and operation phases, which are illustrated in Drawing nos. VI-001 to -003.

10.5 Planning and Development Control Framework

10.5.1 A review has been undertaken of the current planning intentions, statutory land-use and landscape planning designations for the Study Area. The statutory designations for the Study Area are shown on the draft Kam Tin (South) Outline Zoning Plan (see extracts of OZP in Drawing nos. D-001). The proposed secondary drainage channel KT13 is overlaid on the OZP.

10.5.2 According to the covering Notes of the draft Kam Tin South OZP No. S/YL-KTS/9, drainage works are always permitted on land falling within the boundaries of the OZP except where the uses or developments are specified in Column 2 of the Notes of individual zones. Any filling of pond or excavation of land, including that to affect a change of use to any of those specified in Column 1 or 2 above or the uses or developments always permitted under the covering notes (except public works co-ordinated or implemented by Government, and maintenance, repair or rebuilding works), shall not be undertaken or continued on or after the date of first publication in the Gazette of the notice of the interim development permission area plan without the permission from the Town Planning Board under Section 16 of the Town Planning Ordinance (TPO). For area falls within “Conservation Area” (“CA”) , if filling of land/pond or excavation of land, including that to effect a change of use to any of the specified uses in Columns 1 and 2 or the uses or developments always permitted under the covering Notes, permission from the Town Planning Board under section 16 of the TPO is required unless the related works or use are authorised under the Roads (Works, Use and Compensation) Ordinance (Cap.370) or any scheme under the Railways Ordinance shall be deemed to be approved under the TPO.

10.5.3 Hence, subject to the authorization of the Project (including the related works) under the Roads (Works, Use and Compensation) Ordinance (Cap.370), planning permission from the Town Planning Board is not required.

10.5.4 No alteration on planned land use, changes on planning intention and other planned project are envisaged in this study. No impact on future development is hence concluded.

10.6 Comments on Landscape and Visual Issues received during Previous Consultations

Consultations under Previous Studies

10.6.1 Public consultations were undertaken to collection comments from the following social groups on the Project:

· Green Groups (attended by WWF Hong Kong and Kadoorie Farm & Botanic Garden) were consulted on 25 June 2004;

· Kam Tin Rural Committee, Pat Heung Rural Committee and Yuen Long District Council were consulted on in January 2002 and June 2004;

· Local Village Representatives were consulted on September/ October 2004.

10.6.2 No particular comment on landscape and visual aspects was made in the above consultations.

10.7 Baseline Study

Physical, Human and Cultural Landscape Resources

10.7.1 The baseline physical landscape resources that will be affected during the Construction Phase and Operational Phase, together with their sensitivity to change, are described below. The locations of the baseline landscape resources are mapped in Drawing no. LR-001. The Landscape Resources in direct conflict with the Project are mapped together with their extent outside study boundary for integrity of information. Photo views illustrating the landscape resources of the study area are illustrated in Drawing nos. PR-001 to 002 inclusive. For ease of reference and co-ordination between text, tables and figures each landscape resources is given an identity number.

Topography

10.7.2 The landform in the landscape study area which is a natural periodic flooding river valley interspersed with fallowed agricultural land, abandoned fishpond and temporary structures for agricultural and industrial uses. Variety landform and landscape element contribute medium topographical interest or value of the landscape study area.

Drainage

LR1: River/Stream (Photo No. A1, A2, A3, A4 & A5)

10.7.3 There is a semi-natural drainage features (the Ma On Kong Channel) in the study area with untrained natural upstream and partial trained downstream with a total length of 800m. The Channel originates from the South-West of the valley and discharge to the existing Primary Channel by Kam Ho Road running through and along the site area spanning across majority of the river valley, together with the existing vegetations forming the central part of riparian landscape network. They have medium landscape value and sensitive to change.

Fish Pond

10.7.4 There are 4 numbers of fallowed fish ponds at the upstream of the Ma On Kong Channel. A chain of fish ponds near downstream but distant from the Channel is noted. The fish ponds cover area of in total 23,000 m². Most of them are heavily colonized by aquatic plants, which attribute to their low visual quality as a water landscape element. They have low landscape value and sensitive to change.

LR2.1: Fish Pond (within site boundary) (Photo A6)

LR2.2: Fish Pond (outside site boundary) (Photo A7)

Marsh

LR3: Marsh (Photo A8)

10.7.5 It comprises 2 marshes at the upstream channel of the Channel. They are inundated lowland heavily colonized with wetland aquatic plants. They have low landscape value and sensitive to change.

Vegetation

10.7.6 Within the study area, three major types of vegetation are identified according to their habit and origin, namely: Woodland, Orchard/ Horticultural Trees and Low-Lying Agricultural Land/ Fallowed Land. There is no rare, endangered, protected, LCSD Champion Tree, nor Old and Valuable Trees (according to ETWBTC No. 29/2004) within the study boundary or affected by the works. And according to the Cultural Heritage Impact Assessment (Chapter 9), there is no fung shui woodland associated with the nearby villages.

LR4: Woodland/Wooded Area (Photo A9 & A10)

10.7.7 It comprises two major communities of woodland/wooded area. One is dense natural woodland stretching across the Conservation Area and area behind Ma On Kong and consists approximate 450 numbers of trees based on visual estimation. The trees are mainly native species and mature in size It is dominated by Schefflera octophylla, Pinus massoniana, Aporusa chinensis, Celtis sinensis, Bridelia tomentosa, Cinnamomum cmaphora, Rhus chinensis and Rhus succedanea. Another one is a natural more sparse riparian wooded area at upstream of the Channel and consists approximate 60 numbers of trees based on visual estimation. The trees are mainly pioneer species and poorer in form and maturity. It is dominated by Ficus hispida and Macaranga tanarius. They have high landscape value and sensitivity to change.

LR5: Orchard/ Horticultural Trees (Photo A11)

10.7.8 It comprises two groups of trees at downstream below Ma On Kong and north of Ho Pui. Amongst there are approximate 400 numbers of trees based on visual estimation. They are fruit trees and landscape plants of horticultural practices. It is dominated by Dimocarpus longan, Delonix regian, Roystonea regia and Pachira macrocarpa. For their anthropogenic and not permanent in nature, they have medium landscape value and sensitivity to change.

LR6: Low-Lying Agricultural Land/ Fallowed Land (Photo A12)

10.7.9 It comprises fallowed land and agricultural land in low rate of uses. The vegetation is mainly grass and sedge with mosaics of shrubs approaching the Channel. It fills up the about half of the existing landscape within the study area. They have low landscape value and sensitivity to change.

Sitting-Out Area

LR7: Sitting-Out Area at Ma On Kong (Photo A13)

10.7.10 It is located at the Ma On Kong next to the access road. It is a small sitting-out area primarily hard-paved with only 3 amenity trees and one pavilion. It has low landscape value and sensitivity to change.

Landscape Character Areas

10.7.11 Several Landscape Character Areas (LCA) have been identified within the study boundary. These are described below and indicated on Drawing no. LC-001. Photos of these LCAs are shown in Drawing nos. PC-001 to 003.

LCA1: Agricultural Landscape Character Area (Photo B1 & B2)

10.7.12 This comprises fallowed land & agricultural land not in active uses. This character area is flat and gentle sloping in landform and vegetated with grass of various heights. It forms the majority of the landscape character of the entire river valley and the connecting landscape element between other landscape character areas. The sensitivity to change of this area is low.

LCA2: Woodland Landscape Character Area (Photo B3)

10.7.13 This is natural woodland between southern Ma On Kong and the Channel extending up to the access road behind Ma On Kong. The trees are mature in size forming a close woodland landscape. It is the location of egretry of conservation importance. The sensitivity to change of this area is high.

LCA3: River/Stream Landscape Character Area (Photo B4, B5, B6 & B7)

10.7.14 This is the main stream of the Channel in associate with its riparian vegetation. It meanders through the river valley landscape. It is used as a receptor of agricultural effluent from poultry farm around upstream, which contribute to the polluted appearance of the character area around upstream. The sensitivity to change of this area is medium.

LCA4: Fish Pond Landscape Character Area (Photo B8)

10.7.15 This comprises a number of fish ponds of various sizes distributed about the Channel. Most of them are abandoned or with limited uses and colonized with aquatic plants. The sensitivity to change of this area is medium.

LCA5: Village Landscape Character Area (Photo B9 & B10)

10.7.16 This comprises the four major village type rural settlement encompassing Tai Kek, Ma On Kong, Ho Pui and north of Ho Pui. Except Tai Kek which is less revitalized and actively resided, all other three are actively resided. This area is lightly urbanized with low rise village house. The sensitivity to change of this area is low.

LCA6: Industrial Landscape Character Area (Photo B11 & B12)

10.7.17 This comprise collection of slummy-built temporary structure and open storage uses land, which are characterized with metallic hoarding and used for poultry, recycling, vehicle repairing etc. The sensitivity to change of this area is low.

LCA7: Nullah Landscape Character Area (Photo B13)

10.7.18 This is the trained nullah next to Kam Ho Road. It is the primary tributary connecting and receiving outflow from the Ma On Kong Channel. The area is man-made and with poor and monotonous riverside vegetation. The sensitivity to change of this area is low.

Visual Character

10.7.19 The visual quality of the river valley of Ma On Kong Channel is semi-natural based on combination of rural landscape elements including agricultural land, village houses, woodland and pond and stream and industrial landscape elements including open storage and temporary structures. Interspersed landscape elements on general flat landform with minor undulation render numerous small enclosed views. No major vista and high quality open view identified.

Visual Sensitive Receiver (VSR)

10.7.20 Within the ZVI, a number of key Visual Sensitive Receivers (VSRs) have been identified. These VSRs are mapped in Drawing V-001. They are listed, together with their sensitivity, in Table 10.5. Photo views illustrating the VSRs are illustrated in Drawing nos. PV-001 to 002 inclusive. For ease of reference, each VSR is given an identity number, which is used in the text, tables and figures.

Industrial VSRs

I1 : Open Storage near junction between Kam Ho Road and village access (Photo C1)

10.7.21 The VSRs is workers of the open storage. The number of individual is very few and their sensitivity to visual impacts is low.

I2 : Plant Nursery at the east of Ma On Kong Channel (Photo C2)

10.7.22 The VSRs is workers of the plant nursery. The number of individual is very few and their sensitivity to visual impacts is low.

I3 : Plant Nursery at the west of the Ma On Kong Channel (Photo C3)

10.7.23 The VSRs is workers of the plant nursery. The number of individual is very few and their sensitivity to visual impacts is low.

I4 : Temporary Structure for poultry east to Ho Pui (Photo C4)

10.7.24 The VSRs is workers of the temporary structure. The number of individual is very few and their sensitivity to visual impacts is low.

I5 : Open Storage at the end of village access road(Photo C5)

10.7.25 The VSRs is workers of the open storage. The number of individual is very few and their sensitivity to visual impacts is low.

I6 : Temporary Structure for poultry and Open Storage at upstream of Ma On Kong Channel(Photo C6)

10.7.26 The VSRs is workers of the temporary structure and open storage. The number of individual is very few and their sensitivity to visual impacts is low.

Open Space/ Sitting-Out Area VSRs

O1 : Users of Sitting-out Area at Ma On Kong (Photo C7)

10.7.27 The VSRs is future users of the re-provided sitting-out area during operation phase. The number of individual is few and their sensitivity to visual impacts is medium.

Residential VSRs

R1 : Tai Kek (Photo C8)

10.7.28 The VSRs is residents of the village. The number of individual is very few and their sensitivity to visual impacts is high.

R2 : North of Ma On Kong (Photo C9)

10.7.29 The VSRs is residents of the village. The number of individual is very few and their sensitivity to visual impacts is high.

R3 : Ma On Kong (Photo C10)

10.7.30 The VSRs is residents of the village. The number of individual is few and their sensitivity to visual impacts is high.

R4 : North of Ho Pui (Photo C11)

10.7.31 The VSRs is residents of the village. The number of individual is few and their sensitivity to visual impacts is high.

Transport-related VSRs

T1 : Motorists and Pedestrians along village access road (lower section) (Photo C12)

10.7.32 The VSRs is the road users of the road section. The number of individual is few and their sensitivity to visual impacts is low.

T2 : Motorists and Pedestrians along village access road (higher section) (Photo C13)

10.7.33 The VSRs is the road users of the road section. The number of individual is very few and their sensitivity to visual impacts is low.

T3 : Motorists, Pedestrians and Tourists along access road toward Ho Pui Reservoir (Photo C14)

10.7.34 The VSRs is the road users of the road section, part of which are tourist to Ho Pui Reservoir. The number of individual is very few and their sensitivity to change is low.

Assessment on Sensitivity to Change of VSRs

10.7.35 The VSRs are assessed according to the assessment criteria and factors described in Section 10.3.3 Availability and amenity of alternative is not considered as there is no alternative view for the VSRs. The analysis of the assessment is summarized and listed below:

VSRs	VSR attribute	Number of individuals (Many/ Fair/ Few/ Very Few)	Quality of Existing View (Good/ Fair/ Poor)	Availability and amenity of alternative Views	Minimum Distance between VSRs and Impact Source	Degree of Visibility (Full/ Partial/ Glimpse)	Frequent of View (Very Frequent/ Frequent/ Occasional/rare)	Sensitivity of Change
I1	Industrial workers	Very Few	Poor	Not available	5m	Partial	Occasional	Low
I2	Industrial workers	Very Few	Poor	Not available	4m	Partial	Occasional	Low
I3	Industrial workers	Very Few	Poor	Not available	7m	Full	Occasional	Low
I4	Industrial workers	Very Few	Poor	Not available	8m	Full	Occasional	Low
I5	Industrial workers	Very Few	Poor	Not available	12m	Partial	Occasional	Low
I6	Industrial workers	Very Few	Poor	Not available	70m	Partial	Occasional	Low
O1	Sitting-out area users	Few	Fair	Available, Fair	0m	Full	Frequent	Medium
R1	Local Residents	Very Few	Good	Not available	60m	Partial	Occasional	High
R2	Local Residents	Very Few	Fair	Not available	40m	Full	Frequent	High
R3	Local Residents	Few	Fair	Not available	7m – 50m	Full to Partial	Frequent	High
R4	Local Residents	Few	Good	Not available	30m	Glimpse	Frequent	High
T1	Motorists and Pedestrians	Few	Fair	Available, Fair	0m	Full to Partial	Frequent	Low
T2	Motorists and Pedestrians	Very Few	Fair	Available, Fair	0m	Full to Partial	Occasional	Low
T3	Motorists and Tourists	Very Few	Good	Available, Fair	130m	Partial to Glimpse	Occasional	Low

10.8 Landscape Impact Assessment

Potential Sources of Impacts

10.8.1 The nature and scope of works are described in detail in Section 2. For ease of reference, the extent of works at ground level, including all contractor’s temporary works areas, are shown on all the plans illustrating landscape and visual impacts in this section and in Figures 2.2A & 2.2B.

10.8.2 The Project will create varying levels of impact on the landscape resources and landscape character of the surrounding areas during the construction stage. Potential sources of Landscape and Visual Impacts during the Construction Phase of the Project life cycle will include:

· construction of two sections (about 400m and 300m in length) of trapezoidal channel with gabion bank and bed ;

· construction of about 400m long twin cells concrete culvert;

· construction of ancillary infrastructure including vehicular/ pedestrian crossing, pipe crossing, access track, maintenance access with grasscrete surface, footpath, etc;

· site clearance works involving the removal of existing vegetation;

· construction of site access;

· excavation works for the works;

· haulage off-site of excavated materials;

· materials stockpiling;

· temporary traffic/road diversions;

· importation and storage of construction equipment and plant;

· Contractor’s temporary works areas, including site accommodation and parking areas etc; and

· storage of existing topsoil for reinstatement works.

Nature and Magnitude of Unmitigated Landscape Impacts in Construction Phase

Impacts on Landscape Resource

10.8.3 The magnitude of the impacts, before implementation of mitigation measures, on the landscape resources that would occur in the construction phase are described below and tabulated in Table 10.4. All impacts are adverse unless otherwise stated. Magnitude of Impact on LR2.2 Fish Pond (outside site boundary) and LR3 Marsh is negligible since they will not be affected by the works.

River/ Stream

LR1 River/ Stream

10.8.4 There will be permanent and irreversible impact on the existing Ma On Kong Channel due to the construction of trapezoidal channel. Approximate 800m of natural river will be trained with its embankments and substratum converted to gabion. The magnitude of impact on it is large.

Fish Pond

LR2.1 Fish Pond (within site boundary)

10.8.5 There will be permanent and irreversible impact on the existing fish ponds proximate to the works site. Approximate 830m² of the fish ponds will be filled with soil and form part of the trained Channel and embankment. The magnitude of impact on it is large.

Vegetation

LR4 Woodland/Wooded Area

10.8.6 There will be permanent and irreversible impact on the existing woodland. Approximately 44 numbers of trees at the upstream of the Channel will be directly affected by the proposed trapezoidal channel and bypass culvert of which approximately 10 and 34 numbers of trees will be transplanted and felled respectively. There will also be some temporary and reversible impact on the existing woodland. There will be approximately 29 trees within the proposed works area in which trees may be temporarily affected and will be retained on-site. The magnitude of impact on it is intermediate.

LR5 Orchard/ Horticultural Trees

10.8.7 There will be permanent and irreversible impact on the existing orchard/ horticultural trees. Approximately 90 numbers of trees in the orchard/ horticultural trees will be directly affected by the proposed trapezoidal channel of which approximately 50 and 40 numbers of trees will be transplanted and felled respectively. There will also be some temporary and reversible impact on the orchard/ horticultural trees. There will be approximately 30 trees within the proposed works area in which trees may be temporarily affected and will be retained on-site. The magnitude of impact on it is large.

10.8.8 The directly affected trees are proposed to be felled or transplanted. The approximate quantity of trees under these two treatment categories as well as trees to be retained for the two vegetation landscape resource is summarized below:

Landscape Resource	Tree to be Retained	Tree to be Transplanted	Tree to be Felled
LR4	Approx. 29 nos.	Approx. 10 nos.	Approx. 34 nos.
LR5	Approx. 30 nos.	Approx. 50 nos.	Approx. 40 nos.
Total	Approx. 59 nos.	Approx. 60 nos.	Approx. 74 nos.

Sitting-Out Area

LR7 Sitting-out area at Ma On Kong

10.8.9 There will be temporary and reversible impact on the existing sitting-out area at Ma On Kong. The sitting-out area will be removed for construction of the proposed box culvert. 3 amenity trees in the sitting-out area will be affected. However, after completion of major channel works, the sitting-out area will be re-provided. The magnitude of impact on it is small.

Impacts on Landscape Character Area

10.8.10 The magnitude of the impacts, before implementation of mitigation measures, on the landscape character areas that would occur in the construction phase are described below and tabulated in Table 10.4. All impacts are adverse unless otherwise stated.

LCA1 Agricultural Landscape Character Area

10.8.11 There will be permanent and irreversible impact on the agricultural landscape due to land alienation and vegetation loss to the proposed works. The magnitude of impact on it is small.

LCA2 Woodland Landscape Character Area

10.8.12 There will be permanent and irreversible impact on the woodland landscape due to land alienation and vegetation loss to the proposed works. The magnitude of impact on it is intermediate.

LCA3 River/ Stream Landscape Character Area

10.8.13 There will be permanent and irreversible impact on the river/ stream landscape due to the construction of trapezoidal channel and conversion of embankments and substratum to gabion at Ma On Kong Channel. The magnitude of impact on it is large.

LCA4 Fish Pond Landscape Character Area

10.8.14 There will be permanent and irreversible impact on the fish ponds landscape due to loss of fish ponds by soil filling. The magnitude of impact on it is small.

LCA6 Industrial Landscape Character Area

10.8.15 There will be permanent and irreversible impact on the industrial landscape due to land alienation to the proposed works. The magnitude of impact on it is small.

Nature and Magnitude of Unmitigated Landscape Impacts in Operation Phase

10.8.16 The magnitude of the impacts, before implementation of mitigation measures, on the landscape resources and landscape character areas that will occur in the operation phase are the same as the permanent and irreversible impacts described above for the construction phase. They are tabulated in Table 10.4. All impacts are adverse unless otherwise stated.

Landscape and Visual Mitigation Measures in Construction and Operational Phases

10.8.17 The proposed landscape and visual mitigation measures in the construction and operational phases are listed in Tables 10.2 and 10.3 below, together with an indication of Funding, Implementation, Management and Maintenance Agencies. The management and maintenance agency(s) to uptake the management and maintenance of the landscape mitigation measures are identified as per WBTC No. 14/2002 and ETWBTC No. 2/2004. Generally, all landscape mitigation measures are to be implemented as early as possible and many of these mitigation measures perform multiple functions as illustrated in Drawing nos. LP-001 to 002.

Table 10.2 Proposed Construction Phase Landscape Mitigation Measures

ID No.	Landscape Mitigation Measure	Funding Agency	Implementation Agency
CM1*	Topsoil, where identified, should be stripped and stored for re-use in the construction of the soft landscape works, where practical.	DSD	DSD
CM2⁺	Temporary access to site should be planned with care and located to minimize disturbance to existing riparian vegetation.	DSD	DSD
CM3*	Existing trees to be retained on site should be carefully protected during construction.	DSD	DSD
CM4	Trees unavoidably affected by the works should be transplanted where practical.	DSD	DSD
CM5	Compensatory tree planting should be provided to compensate for felled trees.	DSD	DSD
CM6	Erection of decorative screen hoarding compatible with the surrounding rural setting	DSD	DSD

Note:

(1) * Mitigation measures refer to Good Site Practices.

(2) ⁺ Mitigation measures as per DSDTC No. 2/2004.

Table 10.3 Proposed Operation Phase Landscape Mitigation Measures

ID No.	Landscape Mitigation Measure	Funding Agency	Implementation Agency	Maintenance/ Management Agency
OM1	Buffer Planting of Tree and Shrub to screen off and blend in the channel with the adjacent settings	DSD	DSD	DLO
OM2	Compensation Planting of tree and bamboo species as recommended in Ecological Impact Assessment (Section 4.9) compensates and reinstates riparian woodland disturbed on top of hydroseeding.	DSD	DSD	AFCD
OM3	Gabion embankment and substratum for natural colonization of vegetation	DSD	DSD	DSD
OM4	Chromatic treatment of Vehicular and Pedestrian Crossing to match adjacent setting	DSD	DSD	DO for pedestrian crossing
OM5	Aesthetic/ Quality design to re-provision of sitting out area of Ma On Kong	DSD	DSD	LCSD
OM6	Approximate 50m stretch of grasscrete lined maintenance access road within CA zone	DSD	DSD	DSD

Note:

(1) Maintenance/ Management Agencies is in line with WBTC No. 14/2002 & ETWBTC No. 2/2004.

Details of Compensatory Planting as Landscape Mitigation Measure

10.8.18 The planting arrangement of compensatory planting will consider both the Landscape Mitigation Measures as proposed in Table 10.2 and 10.3 and the compensatory planting recommended in Ecological Impact Assessment of this report (Section 4.9) to address both landscape visual and ecological mitigation need. The species for the compensatory planting will be as per recommendation stated in the said ecological section. A brief summary on the general size, quantity and species of proposed landscape mitigation measure is provided below as a list:

Size of Compensatory Tree Planting:	at least heavy standard size
Quantity of Compensatory Tree Planting:	2 times of the tree to be felled (approximately 148 nos. of tree to be compensated)
Proposed Species (as per ecological section):	Bambusa eutuldoides (see requirements below) Celtis tetranda Cinnamomum camphora Ficus virens Ficus microcarpa
Requirements:	To ensure the right species of bamboo is planted, an experienced botantist shall be acquired by the Contractor to source the correct bamboo species. In addition, to ensure that planting of the bamboo for screening to be effective, the bamboos should have a minimum stem diameter of 8-10 cm and clump size of 5 shoots per plant.

Programme of Implementation of Landscape and Visual Mitigation Measures

10.8.19 The Construction Phase measures listed above should be adopted from the commencement of construction and should be in place throughout the entire construction period.

10.8.20 The Operation Phase measures listed above should be adopted during the detailed design, and be built as part of the construction works so that they are in place at the date of commissioning of the Project. However, it should be noted that the full effect of the soft landscape mitigation measures would not be appreciated for several years - the photomontages in Drawing no. PM-001 to 004 illustrate the appearance after 10 years.

Prediction of Significance of Landscape Impacts

10.8.21 The potential significance of the landscape impacts during the construction and operation phases, before and after mitigation, is provided below in Table 10.4. The residue landscape impacts for the construction and operational phases after mitigation are mapped in Drawing nos. LCI-001 to 003 and LRI-001 to 003. This assessment follows the proposed methodology and assumes that the appropriate mitigation measures identified in Tables 10.2 and 10.3 above would be implemented, and that the full effect of the soft landscape mitigation measures would be realized after ten years.

10.8.22 The Operation Phase measures listed above should be adopted during the detailed design, and be built as part of the construction works so that they are in place at the date of commissioning of the Project. However, it should be noted that the full effect of the soft landscape mitigation measures would not be appreciated for several years - the photomontages in Drawing no. PM-001 to 004 illustrate the appearance after 10 years.

Residual Landscape Impacts in Construction Phase

10.8.23 Residual impacts on landscape resources in the Construction Phase are mapped in Drawing no. LRI-001. Residual impacts on landscape character areas in the Construction Phase are mapped in Drawing no. LCI-001. In the Construction Phase, after the implementation of the proposed mitigation measures, there will still be some adverse residual landscape impacts are described below:

LR1 – River/ Stream:

10.8.24 The extent of disturbance from the works is minimized as much as possible and area of site access and stockpiling are carefully allocated to minimize disturbance to riparian vegetation. The residual impact is moderate.

LR2.1 – Fish Pond (within site boundary):

10.8.25 The extent of disturbance from the works to the fish ponds are minimized as much as possible. The residual impact is slight.

LR4 – Woodland:

10.8.26 The works will be adjusted as much as possible to reduce confliction with the exiting trees. Inevitably affected trees will be selected for transplanting as appropriate. However, the tree form and health after transplanting has to be compromised. The residual impact is slight.

LR5 – Orchard/ Horticultural Trees:

10.8.27 The works will be adjusted as much as possible to reduce confliction with the exiting trees. Transplanting of tree will be conducted as long as feasible on the trees affected. However, the tree form and health after transplanting will be inevitably compromised. The residual impact is slight.

LR6 – Low-lying Agricultural Land/ Fallow Land:

10.8.28 Site clearance will be adjusted to minimize the vegetation to be disturbed. The residual impact is slight

LR7 – Sitting-out Area:

10.8.29 The existing amenity tree will be transplanted off site and replanted in reinstatement. The residual impact is slight.

LCA2 – Woodland Landscape Character Area:

10.8.30 The extent of disturbance from the works on the woodland are minimized as much as possible and area of site access and stockpiling are directed away from woodland area to conserve the existing trees. The residual impact is slight.

LCA3 – River/ Stream Landscape Character Area:

10.8.31 The extent of disturbance from the works on the Channel are minimized as much as possible to conserve the existing river character. However, the landscape character of the area will be significantly changed during operation of the construction activity. The residual impact is considered moderate.

10.8.32 Residual landscape impact on other landscape resources and landscape character in Construction Phase is insubstantial.

Residual Landscape Impacts in Operation Phase

10.8.33 Residual impacts on landscape resource and landscape character areas in the Operational Phase are mapped in Drawing no. LRI-002 to 003 and LCI-002 to 003 respectively. In the Operational Phase, after the implementation of the proposed mitigation measures, there will still be no significant residual impact on the landscape resource and landscape character, all ranging from slight to insubstantial. After 10 years of implementation of the proposed mitigation measures, all the residual impact on landscape resource and landscape character areas are insubstantial.

Id. No.	Landscape Resources / Landscape Characters	Sensitivity to Change (Low, Medium, High)	Magnitude of Change (Negligible, Small, Intermediate, Large)	Impact Significance Threshold BEFORE Mitigation (Insubstantial, Slight, Moderate, Substantial)	Recommended Mitigation Measures	Residual Impact Significance Threshold AFTER Mitigation (Insubstantial, Slight, Moderate, Substantial)
Part 1 – Landscape Resource
LR1	River/ Stream	Medium	Medium	Large	Large	Moderate	Moderate	CM2, OM3	Slight	Slight	Insubstantial
LR2.1	Fish Pond (within in site boundary)	Low	Low	Large	Large	Moderate	Moderate	CM2,	Slight	Slight	Insubstantial
LR2.2	Fish Pond (outside site boundary)	Low	Low	Negligible	Negligible	Insubstantial	Insubstantial	-	Insubstantial	Insubstantial	Insubstantial
LR3	Marsh	Medium	Medium	Negligible	Negligible	Insubstantial	Insubstantial	-	Insubstantial	Insubstantial	Insubstantial
LR4	Woodland	High	High	Intermediate	Intermediate	Moderate	Moderate	CM1, CM4 to CM5 OM2	Slight	Slight	Insubstantial
LR5	Orchard/ Horticultural Trees	Medium	Medium	Large	Large	Moderate	Moderate	CM1, CM4 to CM5 OM2	Slight	Slight	Insubstantial
LR6	Low-lying Agricultural Land/ Fallow Land	Low	Low	Small	Small	Slight	Slight	CM1 to CM5 OM2	Slight	Insubstantial	Insubstantial
LR7	Sitting-out area at Ma On Kong	Low	Low	Large	Large	Moderate	Moderate	CM1, CM3 to CM5 OM5	Slight	Insubstantial	Insubstantial
Part 2 – Landscape Character
LCA1	Agricultural Landscape Character Area	Low	Low	Small	Small	Slight	Slight	CM1 to CM5 OM2	Insubstantial	Insubstantial	Insubstantial
LCA2	Woodland Landscape Character Area	High	High	Intermediate	Intermediate	Moderate	Moderate	CM1 to CM5 OM2	Slight	Slight	Insubstantial
LCA3	River/ Stream Landscape Character Area	Medium	Medium	Large	Large	Moderate	Moderate	CM2 &, OM2 to OM4	Moderate	Slight	Insubstantial
LCA4	Fish Pond Landscape Character Area	Medium	Medium	Small	Small	Slight	Slight	CM2 & OM2	Insubstantial	Insubstantial	Insubstantial
LCA5	Village Landscape Character Area	Low	Low	Negligible	Negligible	Insubstantial	Insubstantial	-	Insubstantial	Insubstantial	Insubstantial
LCA6	Industrial Landscape Character Area	Low	Low	Small	Small	Slight	Slight	CM1, CM3 to CM5 OM1	Insubstantial	Insubstantial	Insubstantial
LCA7	Nullah Landscape Character Area	Low	Low	Negligible	Negligible	Insubstantial	Insubstantial	-	Insubstantial	Insubstantial	Insubstantial

Table 10.5 Significance of Visual Impacts in the Construction and Operation Phases (Note: All impacts adverse unless otherwise noted)

VSR Type & ID.	Key Visually Sensitive Receiver (VSR)	Main Source of Visual Impact & Degree of Visibility (Full, Partial, Glimpse)	Minimum Distance Between VSR & Source(s) of Impact	Receptor Sensitivity & Number (Low, Medium, High) (Very Few, Few, Many, Very Many)		Magnitude of Impact (Negligible, Small, Intermediate, Large)		Impact Significance Threshold BEFORE Mitigation (Insubstantial, Slight, Moderate, Substantial)		Recommended Mitigation Measures	Residual Impact Significance Threshold AFTER Mitigation (Insubstantial, Slight, Moderate, Substantial)
										Recommended Mitigation Measures	Construction	Operation
				Construction	Operation	Construction	Operation	Construction	Operation			DAY 1	YEAR 10
I1	Open Storage near junction between Kam Ho Road and village access road	Partial	5m	Low/ Very Few	Low/ Very Few	Intermediate	Intermediate	Slight	Insubstantial	CM1 to CM6 OM1 to OM4	Slight	Insubstantial	Insubstantial
I2	Plant Nursery at the east of Ma On Kong Channel	Partial	4m	Low/ Very Few	Low/ Very Few	Intermediate	Intermediate	Slight	Insubstantial	CM1 to CM6 OM1 to OM4	Slight	Insubstantial	Insubstantial
I3	Plant Nursery at the west of Ma On Kong Channel	Full	7m	Low/ Very Few	Low/ Very Few	Intermediate	Intermediate	Slight	Slight	CM1 to CM6 OM1 to OM4	Slight	Insubstantial	Insubstantial
I4	Temporary structure for poultry east to Ho Pui	Full	8m	Low/ Very Few	Low/ Very Few	Intermediate	Intermediate	Slight	Slight	CM1 to CM6 OM1 to OM2	Slight	Insubstantial	Insubstantial
I5	Open Storage at the end of village access road	Partial	12m	Low/ Very Few	Low/ Very Few	Intermediate	Intermediate	Slight	Insubstantial	CM1 to CM6 OM1 to OM3	Slight	Insubstantial	Insubstantial
I6	Temporary structure for poultry and Open Storage at upstream of Ma On Kong Channel	Partial	70m	Low/ Very Few	Low/ Very Few	Small	Small	Slight	Insubstantial	CM1 to CM6 OM1 to OM3	Slight	Insubstantial	Insubstantial
O1	Users of Sitting-out area at Ma On Kong	Full	0m	N.A.	Medium/ Few	N.A.	Large	N.A.	Moderate	CM1 to CM6 OM1, OM2, OM4	N.A.	Slight	Insubstantialt
R1	Tai Kek	Partial	60m	High/ Very Few	High/ Very Few	Small	Small	Moderate	Insubstantial	CM1 to CM6 OM1 and OM2	Slight	Insubstantial	Insubstantial
R2	North of Ma On Kong	Full	40m	High/ Very Few	High/ Very Few	Intermediate	Intermediate	Moderate	Moderate	CM1 to CM6 OM1 and OM2	Slight	Slight	Insubstantial
R3	Ma On Kong	Full to Partial	7m- 50m	High/ Few	High/ Few	Large	Large	Subtantial	Substantial	CM1 to CM6 OM1 to OM5	Moderate	Moderate	Slight
R4	North of Ho Pui	Glimpse	30m	High/ Few	High/ Few	Intermediate	Intermediate	Moderate	Moderate	CM1 to CM6 OM1 and OM2	Slight	Insubstantial	Insubstantial
T1	Motorists and Pedestrians along village access road (lower section)	Full to Partial	0m	Medium/ Few	Low/ Few	Large	Large	Moderate	Moderate	CM1 to CM6 OM1 to OM4	Slight	Insubstantial	Insubstantial
T2	Motorists and Pedestrians along village access road (higher section)	Full to Partial	0m	Medium/ Very Few	Low/ Very Few	Large	Large	Moderate	Moderate	CM1 to CM6 OM1 to OM4	Sight	Insubstantial	Insubstantial
T3	Motorists, Pedestrians and Tourists along access road toward Ho Pui Reservoir	Partial to Glimpse	130m	Low/ Very Few	Low/ Very Few	Small	Small	Moderate	Insubstantial	CM1 to CM6 OM1 to OM4	Slight	Insubstantial	Insubstantial
* I = Industrial; O = Open space/ Sitting-out Area; R = Residential; T = Transport related (land).

VSRs	Scale of Development (Large/ Intermediate/ Small)		Compatibility of Project with visual context (Good/ Fair/ Poor)		Reversibility of Impact		Minimum Distance between VSRs and Impact Source	Degree of Visibility (Full/ Partial/ Glimpse)	Frequent of View (Very Frequent/ Frequent/ Occasional/rare)	Magnitude of Impact
VSRs	Construction	Operation	Construction	Operation	Construction	Operation	Minimum Distance between VSRs and Impact Source	Degree of Visibility (Full/ Partial/ Glimpse)		Construction	Operation
I1	Intermediate	Intermediate	Poor	Fair	No	No	5m	Partial	Occasional	Intermediate	Intermediate
I2	Intermediate	Intermediate	Poor	Fair	No	No	4m	Partial	Occasional	Intermediate	Intermediate
I3	Intermediate	Intermediate	Poor	Fair	No	No	7m	Full	Occasional	Intermediate	Intermediate
I4	Intermediate	Intermediate	Poor	Fair	No	No	8m	Full	Occasional	Intermediate	Intermediate
I5	Intermediate	Intermediate	Poor	Fair	No	No	12m	Partial	Occasional	Intermediate	Intermediate
I6	Small	Small	Poor	Fair	No	No	70m	Partial	Occasional	Small	Small
O1	N.A.	Intermediate	N.A.	Fair	N.A.	No	0m	Full	Frequent	N.A.	Large
R1	Small	Small	Poor	Fair	No	No	60m	Partial	Occasional	Small	Small
R2	Small	Small	Poor	Fair	No	No	40m	Full	Frequent	Intermediate	Intermediate
R3	Intermediate	Intermediate	Poor	Fair	No	No	7m	Full to Partial	Frequent	Large	Large
R4	Small	Small	Poor	Fair	No	No	30m	Glimpse	Frequent	Intermediate	Intermediate
T1	Intermediate	Intermediate	Poor	Fair	No	No	0m	Full to Partial	Frequent	Large	Large
T2	Intermediate	Intermediate	Poor	Fair	No	No	0m	Full to Partial	Occasional	Large	Large
T3	Small	Small	Fair	Fair	No	No	130m	Partial to Glimpse	Occasional	Small	Small

CM1	Topsoil, where identified, should be stripped and stored for re-use in the construction of the soft landscape works, where practical.
CM2	Temporary access to site should be planned with care and located to minimize disturbance to existing riparian vegetation.
CM3	Existing trees to be retained on site should be carefully protected during construction.
CM4	Trees unavoidably affected by the works should be transplanted where practical.
CM5	Compensatory tree planting should be provided to compensate for felled trees.
CM6	Erection of decorative screen hoarding compatible with the surrounding rural setting

OM1	Buffer Planting of Tree and Shrub to screen off and blend in the channel with the adjacent settings
OM2	Compensation Planting of tree and bamboo species as recommended in Ecological Impact Assessment (Section 4.9) compensates and reinstates riparian woodland disturbed on top of hydroseeding.
OM3	Gabion embankment and substratum for natural colonization of vegetation
OM4	Chromatic treatment of Vehicular and Pedestrian Crossing to match adjacent setting.
OM5	Aesthetic/ Quality design to re-provision of sitting out area of Ma On Kong
OM6	Approximate 50m stretch of grasscrete lined maintenance access road within CA zone