14.1          General

This EIA Report has provided an assessment of the potential environmental impacts associated with the construction and operation of the proposed LT/HYW BCP and Connecting Road, based on the preliminary engineering design information available at this stage.

The assessment has been conducted in accordance with the EIA Study Brief (No. ESB-199/2008) issued under the Environmental Impact Assessment Ordinance (EIAO) for the Project, covering the following environmental issues:

¡      Air Quality Impact

¡      Noise Impact

¡      Water Quality Impact

¡      Sewerage and Sewage Treatment Implications

¡      Waste Management Implications

¡      Land Contamination

¡      Ecological Impact

¡      Fisheries Impact

¡      Landscape, Visual and Glare Impact

¡      Cultural Heritage Impact

The findings of this EIA study have determined the likely nature and extent of environmental impacts predicted to arise from the construction and operation of the Project. During the EIA process, environmental controls measures have been identified and incorporated into the planning and design of the proposed LT/HYW BCP and Connecting Road, to ensure compliance with environmental legislation and standards during both the construction and operation phases. The implementation schedule detailing the recommended mitigation measures are presented in Section 15.

The EIA study for the proposed LT/HYW BCP and Connecting Road has predicted that the Project, with implementation of the recommended mitigation measures, would be environmentally acceptable with no adverse residual impacts on the population and environmentally sensitive resources. The environmental outcomes/benefits that have accrued from the environmental considerations and analysis during the EIA process and the implementation of environmental control measures of the Project are summarised in the following sections. Environmental monitoring and audit requirements have been recommended, where necessary, to check on project compliance with environmental legislation and standards.

14.2          Summary of Environmental Outcomes, Benefits and Mitigation Measures

14.2.1       The Project

The scope of the Project comprises:

(i)               site formation for the construction of a BCP building in the area of Chuk Yuen Village;

(ii)              drainage facilities discharging into the Shenzhen River associated with the BCP;

(iii)            cargo processing facilities including processing kiosks for clearance of goods vehicles, vehicle holding areas, customs inspection platforms, cargo examination buildings, X-ray building, weigh stations etc.;

(iv)             passenger related facilities including processing kiosks and examination facilities for private cars and coaches, passenger clearance building and halls, etc.;

(v)              accommodation for and facilities of the Government departments providing services in connection with the BCP;

(vi)             provision of transport related facilities inside the BCP including public transport interchange, and transport drop-off and pick-up areas;

(vii)           other peripheral structures and supporting facilities such as bridges across Shenzhen River, border road and fences, water supply system, utilities, culvert, drainage and sewerage etc.;

(viii)          construction of a dual two-lane trunk road with traffic control and surveillance system connecting the BCP with Fanling Highway adjacent to Wo Hop Shek - which comprises approximately 5.2km of viaduct and/or at grade sections, and two tunnel sections totalling 5.7km in length, tunnel administration building and tunnel ventilation system;

(ix)            associated diversion / modification works at Lin Ma Hang Road to cope with the BCP development;

(x)             associated environmental mitigation measures, landscaping works, drainage/ sewerage, waterworks, utilities and traffic engineering works; and

(xi)            collection, treatment and disposal of sewage generated from the BCP via provision of an on-site sewage treatment facility to a tertiary level with proposed Membrane Bioreactor (MBR) treatment and effluent reuse.

14.2.2       Environmentally Friendly Options and Design

Throughout the feasibility and preliminary design stages of the Project, environmental considerations have been a key component of the assessment process. The BCP and Connecting Road alignment has gone through a number of options assessments to arrive at the current preferred option, which is weighted towards achieving a more environmentally friendly option particularly for the route of the Connecting Road.

As detailed in Section 2.6, the current alignment has undergone several rounds of refinement such that environmentally sensitive areas have been avoided as much as practicable, and environmental concerns from the surrounding population have been addressed or minimised. One of the key options that was adopted to limit environmental impacts on surrounding resources was to opt for an entirely tunnel-based alignment from south of Sha Tau Kok Road to Fanling, thereby avoiding nearly all environmental impacts on this section of the alignment except for the necessary portal and ventilation building areas.

The design of the BCP and Connecting Road has also incorporated a number of landscaping features to alleviate the visual impact from the structures. Within the BCP, extensive green roof and vertical greening have been proposed where appropriate and practicable to improve the visual context of the bulk structures, and the same has been applied to the ventilation buildings. Consideration has also been given to energy efficiency and grey water reuse as part of the design parameters. Along the Connecting Road, consideration has been given to the different construction methods to limit the potential construction phase environmental impacts. For the viaduct structures, pre-cast segmental launching method was recommended, which meets the design requirements while reducing the disturbance to existing topographical features such as river channels. For the tunnels, manual excavation will be employed around sensitive environmental areas such as Tan Shan River to prevent impacts from tunnel blasting, and after construction of the bulk structures is complete, planters have been proposed along the viaduct in addition to extensive planting with tall trees at ground level to provide additional screening. These measures have been incorporated into the design so that the Project can be achieved in an environmentally friendly manner as much as practicable.

14.2.3       Population and Environmentally Sensitive Areas Protected

Based on the current Connecting Road alignment, the following environmental sensitive areas have been avoided and protected;

¡      Kong Yiu Channel – the BCP will be constructed entirely within the lands to the east of the channel hence realignment of the channel is no longer required and the existing channel can be left undisturbed.

¡      Pat Sin Leng Country Park – the alignment has avoided encroaching into this protected area.

¡      Tan Shan River – the alignment is in tunnel form and no adverse impacts are anticipated during construction and operation phases.

¡      Fung Shui woodlands – the alignment has avoided encroaching into these ancient woodlands of high ecological and social value.

¡      Designated Archaeological Sites – the alignment has avoided encroaching into any of the sites of high archaeological potential.

The current alignment was also routed to minimise impacts to large populated areas, both during construction and operation phases. The decision to resume the Chuk Yuen village instead of configuring the BCP in between Chuk Yuen and Tsung Yuen Ha has protected both villages from severe environmental impacts that would arise from having the BCP surrounding both villages. At the Sha Tau Kok Road area, the required interchange with Sha Tau Kok Road has been provided while avoiding impacts to the majority of village environs within the area, while at Fanling, the interchange with Fanling Highway has been strategically positioned to avoid impacting on surrounding residential areas while maintaining the functionality of the link between the proposed Connecting Road and existing Highway.

14.2.4       Environmental Problems Avoided and Compensation

As part of the comprehensive selection process to derive at the current Connecting Road alignment option, many environmental issues have been identified early on and problems have been avoided or minimised as best as practicable. The key environmental problems avoided are listed below:

¡      Avoidance of densely populated areas

¡      No direct loss of permitted burial grounds

¡      No additional pollution load to Deep Bay

¡      No disturbance of areas with significant potential for land contamination

¡      No direct impacts to listed or graded cultural heritage features

By re-designing the vertical and horizontal alignment to avoid direct impacts on the aforementioned key areas, impacts to populated areas have been limited, and important archaeological areas and cultural heritage features have been protected. The current alignment has also limited the air, noise and visual impacts by opting for a route with the practicably least number of sensitive receivers in the vicinity of the Project, after striking a balance between the design criteria for the Project and the environmental impacts. Notwithstanding that the Project will impact on some habitats and landscapes, the affected wetland and woodland will be compensated by a ratio of at least 1:1 to ensure no net loss of these habitats, while the number of trees that need to be felled and compensated has been accounted for as part of the landscape assessment. Extensive tree planting has thus been proposed along the Connecting Road alignment and at the reinstated temporary works areas of the ventilation buildings and administration building to provide the required tree compensation numbers.

14.2.5       Environmental Benefits of the Recommended Protection Measures

Highlights of the key environmental protection measures recommended for the Project include the following:

¡      Noise barriers separating sensitive receivers from noisy sections of the alignment;

¡      Tree planting along the alignment, with planters on the viaduct sections to improve the visual context;

¡      Reuse of treated wastewater from the sewage treatment facility for irrigation within the BCP;

¡      Ventilation building louvers located on the facades facing away from as many sensitive receivers as practicable and specification of maximum allowable sound power levels for those louvers;

¡      Extensive landscaping of the existing site around the Mid-Tunnel Ventilation Building and Administration Building;

¡      Preservation or relocation of any flora/fauna species of conservation interest;

¡      Provision of compensation woodland and wetland habitat to mitigate the loss of habitat in secondary woodland and cumulative wetland loss.

With implementation of these measures, the environmental impacts from the Project will be alleviated or reduced to acceptable levels. Sensitive receivers in close proximity to the Project will benefit from the reduction in noise and visual impacts, while important species of flora and fauna will be protected. Some areas of the Project may see an improvement to the original condition due to the implementation of extensive tree planting and landscaping works along the alignment and within the BCP. The reuse of treated wastewater from the BCP will also contribute to environmental benefits due to the water savings and no net increase in pollutant loadings to Deep Bay. 

14.2.6       Air Quality Impact     Construction Phase

The major construction activities of the Project that would contribute to construction dust impacts include excavation/earth work within the work sites (except the tunnel sections), construction of at-grade and viaduct roads, slope work, site formation at the BCP site and construction of superstructure.  No significant fugitive dust emissions would be expected from tunnelling activities. 

With implementation of the recommended mitigation measures as well as the relevant control requirements as stipulated in the Air Pollution Control (Construction Dust) Regulation, no exceedance of the TSP criteria is predicted at all the ASRs during the construction phase.     Operational Phase

 Potential air quality impacts during operational phase include vehicular emissions from open roads, ventilation shafts, mid-ventilation building as well as traffic facilities of the BCP. The assessment results show that no adverse impacts are predicted from road traffic during the operational phase of the Project.

There would also be potential odour impact on nearby ASRs due to the proposed sewage treatment works at the BCP site. With the large buffer distance (over 490m) and the odour containment and control measures in place to substantially confine and reduce the potential odour emissions at sources, it is anticipated that the sewage treatment works would not have significant odour impact on the nearby ASRs. 

14.2.7       Noise Impact     Construction Phase

The noise impact associated with unmitigated construction activities for the proposed BCP and the connecting road would cause exceedance of the daytime construction noise criterion at the nearby NSRs during the normal working hours.  Therefore, good site practices and mitigation measures including the use of quiet plants, erection of movable noise barriers and noise insulating fabric have been proposed to alleviate the noise impact.   With the good site practices and mitigation measures in place, no residual impacts are predicted at all the NSRs.     Operational Phase

The assessment has predicted that the traffic noise impact arising from the proposed connecting roads of the Project and the contribution from existing road network in Year 2033 will exceed the noise criteria at the existing NSRs with around 73 dwellings affected by the Project roads.  With the implementation of mitigation measures recommended, the noise criteria will be met at all representative NSRs with traffic noise impact dominated by the Project roads.

With the specification of maximum allowable sound power levels for the proposed fixed plants at ventilation shafts, mid-ventilation building, BCP buildings and Administration Buildings, full compliance of Noise Control Ordinance will be achieved. 

14.2.8       Water Quality Impact     Construction Phase

The key issue in terms of water quality during the construction phase of the Project would be the potential for release of sediment-laden water from surface works areas and tunnelling works, and the potential for drawdown of groundwater level. 

Deterioration in water quality could be minimised to acceptable levels through implementing adequate mitigation measures such as control measures on sediment release, on site runoff and drainage from the works areas to minimise sediment spillage and construction runoff; pre-injection of grouting prior to tunnelling works supplemented by post-injection of grouting; and on-site treatment of tunnelling wastewater prior to discharge. Proper site management and good housekeeping practices would also be required to ensure that construction wastes and other construction-related materials would not enter the public drainage system and nearby waters. Sewage effluent arising from the construction workforce would also be handled through provision of portable toilets.

With the implementation of these recommended mitigation measures, no unacceptable impacts on water quality from the construction works for the Project are anticipated. Water quality monitoring during the course of construction works at channels and rivers and site inspections during construction phase should be undertaken routinely to inspect the construction activities and works areas to ensure the recommended mitigation measures are properly implemented.     Operation Phase

The operational surface and stormwater runoff would have no adverse water quality impact provided that the recommended mitigation measures are incorporated in the design of the planned drainage system. Sewage arising from the operation of the proposed BCP and associated facilities as well as from the Chuk Yuen Resite will be collected and treated by the recommended sewerage and sewage treatment facilities to fulfil the no net increase in pollutant loading policy. In order to enhance environmental sustainability, reuse of a portion of the treated effluent for irrigation at BCP is recommended.  Thus, no adverse water quality impact during operation phase is anticipated.

14.2.9       Sewerage and Sewage Treatment Implications

The Project will generate sewage flow of 327.56 m3/day from the proposed BCP site and Chuk Yuen Village Resite during the operational phase, which cannot be handled by the SWHSTW or the new sewage treatment plant for NDAs at North District due to mismatch of the programmes.  In order to meet the no net increase in pollutant loading requirement, it is recommended to construct and operate an on-site sewage treatment work using MBR treatment process at the proposed BCP to treat the sewage from the BCP and Chuk Yuen Village Resite.  The design treatment capacity of the treatment facilities is 387.56 m3/day. In addition, to further reduce the discharge of sewage and pollutant loadings, it is also recommended to reuse a portion of the treated effluent (not more than 178.75 m3/day) for irrigation of the landscaping areas and flushing at the BCP. With the recommended sewage treatment and reuse systems, it can be concluded that there will be no adverse sewage impacts due to the Project.

Apart from the sewage to be generated by the proposed BCP and Chuk Yuen Village Resite, a small amount of sewage (12.56 m3/day) will also be generated by the Administration Building to be located at the Sha Tau Kok Road Section (between north and south tunnels) of the Connecting Road. This small amount of sewage is proposed to discharge into the local sewerage system connecting to the SWHSTW.

14.2.10  Waste Management Implications

Wastes generated by the construction activities are likely to include C&D materials from the construction works, general refuse from the workforce and chemical waste from any maintenance of construction plant and equipment. Provided that these identified wastes are handled, transported and disposed of using approved methods and that the recommended good site practices are strictly followed, adverse environmental impacts are not anticipated during construction of the Project.

Waste types generated by the operation activities are likely to include general refuse from the workforce and chemical waste from the maintenance activities. Provided that these wastes are handled, transported and disposed of using approved methods and that the recommended good site practices are strictly followed, adverse environmental impacts is not expected during operation phase.

14.2.11  Land Contamination

The land contamination assessment has been conducted by reviewing historical/current land uses, desktop review and site inspection. Other relevant information was also collected from the related Government Departments.

Based on the findings of the site appraisal on the existing and historical land uses in the Study Area, adverse land contamination impacts associated with the construction and operation of the proposed LT/HYW BCP, connecting roads and ventilation buildings are not expected, except the open area at Sha Tau Road near Loi Tung, works sites of ventilation building in Po Kat Tsai and workshops in Fanling. The potential of land contamination is anticipated to be low at the two sites, while at the remaining areas as insignificant. Site investigations and laboratory chemical analysis are therefore proposed to be conducted upon land acquisition and site access is granted. Contamination Assessment Report (CAR), Remedial Action Plan (RAP) and Remediation Report (RR) would be necessary if land contamination is confirmed.

Mitigation measures for handling of contaminated materials, in case it is discovered after the commencement of works, and regular site audits are recommended to minimize the potential adverse impacts on workers’ health and safety and disposal of potentially contaminated materials.

14.2.12  Ecological Impact

An ecological impact assessment for the proposed project was conducted in accordance with Annexes 8 and 16 of the EIAO-TM. Baseline information on ecological resource was derived from literature review and suitably designed field survey. Ecological field survey was carried out between May 2009 and September 2010, covering both the wet and dry seasons.

A total of 12 habitat types were identified within the Assessment Area, including woodland, shrubland, plantation, freshwater wetland, active agricultural land, abandoned agricultural land, hillside grassland, pond, drainage channel, watercourse, open field and developed area. Literature records revealed a few ecological hotspots within the Assessment Area including a diverse ecological resource in Pat Sin Leng CP, an identified dragonfly hotspot in Tan Shan River, non-flying mammal species of conservation interest in Frontier Closed Area, Ecologically Important Streams and fung shui woods. 

Six fung shui woods namely Heung Yuen Wai, Tsung Yuen Ha, Kan Tau Wai, Man Uk Pin, Loi Tung and Tan Chuk Hang Lo Wai and three Ecologically Important Streams namely Man Uk Pin, Tan Shan River and Kau Lung Hang were identified within Assessment Area. Direct impact on these ecologically sensitive habitats has been avoided in the refined alignment option.   

The identified potential impacts comprise mainly direct loss of habitat and direct/indirect impact on flora and fauna species of conservation interest. Permanent loss of some area (6.2 ha) of secondary woodland would be resulted from the construction of the tunnel portals and sections of the connecting roads but it will be fully mitigated by the provision of 18.6 ha woodland compensation area. For the permanent loss of a total area of 1.4 ha freshwater wetland originated from abandoned agricultural land, it will be compensated with a wetland area of at least 1.4 ha. Details of the above mitigation measures would be formulated and further provided in Woodland Compensation Plan and Habitat Creation and Management Plan respectively under the project during the detailed design stage.     

Four floral species of conservation interest were recorded within the Works Area: Aquilaria sinensis, Cibotium barometz, Euonymus kwangtungensis and Pavetta hongkongensis. Potential impact on Aquilaria sinensis and Euonymus kwangtungensis is anticipated to be of ecological significance and mitigation measures are considered necessary. Healthy and young individuals as well as seedlings of the tree species Aquilaria sinensis should be considered for transplanting. Including the species into the planting schedule for woodland compensation is recommended to mitigate the impact on those individuals unable to be transplanted. The affected shrub species of Euonymus kwangtungensis will be transplanted to undisturbed habitats for preservation. A pre-construction vegetation survey is recommended to be conducted prior to the commencement of construction works to confirm the updated status of these affected plant species of conservation interest in the site and to identify appropriate reception site.

A total of 122 fauna species of conservation interest were identified within the Assessment Area of which only 14 of them were recorded within the Works Area. Given that the area affected under the project are not identified as optimal habitats for the above fauna species and that extensive similar habitat is available in the close vicinity of the project site, potential adverse impacts on fauna species of conservation interest is evaluated as minor under the project. In respect of the major mammal community found in the Frontier Closed Area which is mostly located to the east of the proposed BCP location, the habitat loss impact and fragmentation effect have been minimized through adopting the currently proposed BCP location. Impact on breeding ardeid is minor because the closet egretry in Ping Che is far away from the Works Area and their main flight path will not be obstructed by the proposed Project. Indirect impact on the aquatic community in watercourse is minimal because no channelization and watercourse training works are required, hence no significant hydrological disruption will be resulted.

Habitat fragmentation impact would be minimized with the proposed viaduct design of the Connecting Road and the proposed landscaping measures which allow wildlife crossing. Potential direct impact on the site of conservation importance and any watercourses are avoided in the alignment selection process. With the implementation of proposed mitigation measures, potential indirect impact including vibration, noise, water quality and hydrological disruption and cumulative impacts are evaluated as environmentally acceptable. No residual impacts are anticipated under the project.

14.2.13  Fisheries Impact

The baseline review and ground truthing conducted for fisheries impact assessment have identified no active fishponds, pond fish culture resources or activities within the Study Area.  With the effluent control measures in place, the Project is unlikely to have indirect impacts on the pond fish culture resources and activities in the NWNT area. Therefore, no fisheries impact arising from construction and operation of the Project is anticipated and no fisheries-specific mitigation measures (other than the effluent control measures) are required.

14.2.14  Landscape, Visual and Glare Impact

The LVIA has been prepared is in accordance with Annexes 10 and 18 in the Hong Kong SAR Government's Technical Memorandum on the Environmental Impact Assessment Process (EIAO-TM) under the EIA Ordinance (Cap.499, S16), entitled "Criteria for Evaluating Visual and Landscape Impact" and "Guidelines for Landscape and Visual Impact Assessment", respectively and the EIAO Guidance Note No. 8/2002 “Preparation of Landscape and Visual Impact Assessment under the Environmental Impact Assessment Ordinance.”

The baseline study identified 24 Landscape Resources (LRs) and eleven Landscape Character Areas (LCAs) within the whole Study Area. Within the visual envelopes identified for the four major above ground sections, 39 VSRs of seven different categories, namely Residential (H), Industrial (I), Travelling (T), Mixed Commercial/ Residential (C/R), Occupational (O), Recreational (R) and Other Specified Use (OU), were identified.

Overall, the Project at operation Year 10 is not expected to have any significant or moderate residual impacts on the landscape. For landscape resources and character areas, there are likely to be slight operational residual impacts at Year 10 on LR5.1 (Active Farmland) and LCA3 (Agricultural Lowland Landscape) in Section A, Zone 1; LR3.1 (Woodland on Hillside) and LCA3 (Agricultural Lowland Landscape) in Section A, Zone 2; LR3.1 (Woodland on Hillside), LR3.2 (Woodland on Lowland) and LCA1 (Natural Vegetated Hillside Landscape) in Section A, Zone 3; and LR3.1 (Woodland on Hillside) in Section C. In Section B it is suggested that some beneficial impact may be experiences by LCA7 (Developed Rural Landscape).

With the implementation of mitigation measures, all other residual operational impacts on the landscape will be insignificant.

Overall, the Project at operation is not considered to have any significant residual visual impacts on VSRs. Following the implementation of mitigation measures, there are likely to be moderate operational residual impacts on residents in the areas of Tsung Yuen Ha (H3), Nga Yiu Ha (H7), Village on Wo Keng Shan Road (H8), Ping Yeung East (H9), Village West of Man Uk Pin (H10), Tai Tong Wu (H12), Dawning Views (H18) and Tong Hang (H19).

There are likely to be slight residual impacts on VSRs in the areas of Heung Yuen Wai (H1), Ha Heung Yuen (H2), Re-site of Chuk Yuen Village (H4), Lung Mei Teng (R1), Ping Yeung South Industrial Area (I1), Man Uk Pin (H11), Loi Tung Village (H13), Po Kat Tsai (H15), Lung Shan Temple (OU5), Wo Hop Shek Village (H20), Yuen Leng (H21), Tai Wo (H22), Nam Wa Po (H23), Hong Lok Yuen (H25) and on the Wilson Trail (R2) as well as the future VSRs in the area of the Proposed CDA (Ex-Burma Lines Military site) (H16).

With the implementation of mitigation measures, residual operational impacts on the remaining VSRs, namely those in the areas of Kaw Liu Village (H5), Fung Wong Wu (H6), Graveyard by Poultry Farm (OU1), Graveyard by Kaw Liu Village (OU2), Earth Shrine near Tsung Yuen Ha (OU3), Tin Hau Temple (OU4), Ta Kwu Ling Police Station (O1), Sha Tau Kok Road (T1), Open Storage on Lau Shui Heung Road (I2), Tung Kok Wai (H14), Wing Ning Wai (H17), Fanling Highway (T2), Tai Hang (H24) and Columbarium in Wo Hop Shek Cemetery (OU6), as well as the future VSRs in the Proposed NDA (C/R1), will be insignificant.

The Project will produce some adverse landscape and visual impacts but these can be eliminated, reduced or offset to a large extent by specific measures. Therefore according to Annex 10 of the Technical Memorandum on the Environmental Impact Assessment Process (EIAO-TM), the Landscape and Visual Impacts are considered acceptable with mitigation.

14.2.15  Impact on Cultural Heritage  Archaeological Resources

Two sites of archaeological interest are identified within the CHIA Study Area but outside the works boundary of the Project.  No construction and operation impacts on the two known sites of archaeological interest are anticipated.  Therefore, mitigation measures or monitoring is not required.

With regard to unknown archaeological resources, archaeological potentials of the works area for various sections of the Project have been identified and an archaeological survey proposal of a total of 40 test pits and 62 auger holes was agreed with AMO.  Due to site access constraints, only 16 test pits and 37 auger holes were conducted at the EIA Stage.  The outstanding archaeological survey in Section between Lin Ma Hang and Frontier Closed Area Boundary, Section between Ping Yeung and Wo Keng Shan, Sha Tau Kok Road Section (Between North and South Tunnel), Lau Shui Heung Tunnel Section (South Tunnel) and Fanling Section should be conducted after land resumption before commencement of the construction work of the Project to confirm the findings of the EIA Study.  It should be noted that the scope of further archaeological survey is based on the current proposed alignment.  Any additional works areas which have not been covered by the current archaeological impact assessment should be covered as soon as possible. Subject to findings of the archaeological survey to be conducted after land resumption, additional mitigation measures would be designed and implemented before the commencement of construction works to mitigate the adverse impacts.

In Section between Lin Ma Hang and Frontier Closed Area Boundary, an area with low / medium archaeological potential has been identified.  However, some of the proposed survey works in the area have not been carried out due to site access constraints.  Although it is anticipated that the archaeological potential of these areas will also be low, further survey is required to confirm the preliminary findings.  Therefore, the outstanding survey works should be conducted immediately after land resumption and before commencement of construction works to verify the findings of the EIA.  Moreover, although artefacts were not found from the low archaeological potential area, the test pits results indicated the presence of a layer with human activities.  It is therefore recommended that additional test pits and auger holes are conducted in the concerned area to confirm the archaeological potential

In Section between Ping Yeung and Wo Keng Shan, in-situ late Qing Dynasty cultural layers have been identified in TP0505 and the indicative boundary was defined with low archaeological potential.  The archaeological resources in this area will be directly impacted by the construction works.  A survey-cum-rescue excavation is recommended to be conducted after land resumption and before the commencement of the construction works to further investigate the archaeological remains and to preserve the archaeological remains, if any, confirmed by the survey.

The survey-cum-rescue excavation and outstanding archaeological survey should be conducted by a professional archaeologist who should obtain a licence to Excavate and Search for Antiquities from the Antiquities Authority under the AM Ordinance. An Archaeological Action Plan (AAP) following the Guideline for Cultural Heritage Impact Assessment should be submitted to Antiquities and Monuments Office (AMO). The project proponent should appoint qualified and experienced archaeologist(s) with sufficient funding, time and personnel arrangements to implement the AAP. Details of the proposal plan with specification for further archaeological survey and survey-cum-rescue excavation should be agreed with AMO. The AAP should include , but not limited to, the following information:

¡      a detailed plan for further archaeological survey at inaccessible areas in Section between Lin Ma Hang and Frontier Closed Area Boundary, Section between Ping Yeung and Wo Keng Shan, Sha Tau Kok Road Section (Between North and South Tunnel), Lau Shui Heung Tunnel Section (South Tunnel) and Fanling Section;

¡      a detailed plan for survey-cum-rescue excavation at the Section between Ping Yeung and Wo Keng Shan; and

¡      a contingency plan to address possible arrangement if significant archaeological findings are unearthed during the further archaeological survey and survey-cum-rescue excavation.  Built Heritage Sites

Literature review supplemented by built heritage survey identified one Declared Monument, six grade 3 historic buildings, five nil grade historic buildings, one proposed grade 3 historic building, seventy built structures, twenty graves and eight cultural/historical landscape features within the CHIA Study Area.

Majority of the built heritage sites are located at a long distance from the works boundary.  Thus no direct impacts on these built heritage sites are expected.

Nevertheless, the thirteen grave sites at the proposed BCP building (i.e. GR01, GR02 and GR19), the section between Ling Ma Hang and Frontier Closed Area Boundary (i.e. GR05 and GR06), the section between Ping Yeung and Wo Keng Shan (i.e. GR08, GR10 and GR18), the Cheung Shan Tunnel Section (i.e. GR20) and the Fanling Section (i.e. GR13, GR15, GR16 and GR17), the two built structures located beneath the proposed viaduct structure (i.e. BS64 and BS65) along the section between Ping Yeung and Wo Keng Shan, as well as a cultural/historical landscape feature (i.e. LF08) situated at the proposed BCP building, have been identified to be located within the works boundary of the Project, and thus direct impact on these built heritage sites is anticipated.  

Preservation proposal in the form of mitigation measures are recommended in short and long term in accordance with different Project phases.  During the design stage along with the EIA study process, the design of the Project has considered avoidance of direct impact on identified graves but considered impractical.  Physical relocation/removal of the thirteen affected grave sites as well as the landscape feature is recommended as the last resort prior to commencement of the construction works. Photographic and cartographic records to be conducted for these structures before their removal have been recommended to preserve them by record.

With regard to access to the graves, only that of GR03 will temporarily be affected by the proposed works during construction works. Access diversion will be provided temporarily during the construction phase so that access to the grave will not be blocked as a result of the construction works. Furthermore, after completion of the construction works, the affected access route will be re-provided. Therefore, the proposed works will have temporary impact on the access to the grave during construction phase but no impact is anticipated during operation phase.

The grave site, GR13, is the only built heritage feature identified to be located within the blasting impact area during the construction phase.  However, since it will be removed prior to commencement of the construction work due to its location within the works boundary of the Project, no impact from the proposed blasting work is anticipated for the grave site. 

Avoidance of direct impact on the two built heritage (BS64 and BS65) by slightly shifting the relevant alignment section has been assessed and is not recommended as this will be at the cost of creating various environmental impacts and arousing objections from the nearby community.  Moreover, the two built heritage sites, which are considered as having some but not high heritage value, are regarded as only two built heritage features but not sites of cultural heritage listed by AMO.  Therefore, removal of the two sites is considered necessary as the last resort, and the impact is considered acceptable provided that full photographic and cartographic records should be conducted prior to their removal. 

During the detail design stage of the Project, in case any potential vibration impact on any nearby built heritage features are identified, it is recommended that prior to commencement of the construction works, a baseline condition survey and baseline vibration impact assessment should be conducted by a qualified building surveyor and a qualified structural engineer to define the vibration limit and to evaluate if construction vibration monitoring and structural strengthening measures are required during construction stage to ensure the construction performance meets with the vibration criteria to be agreed with the AMO.