11. Cultural Heritage Impact Assessment

11.1 Introduction

This Chapter presents the cultural heritage including archaeological and built heritage implications of developing OWTF 2 at Sha Ling in the North District, within the Frontier Closed Area.

The Cultural Heritage Impact Assessment (CHIA) assessed both the site area (SA), which will be impacted directly, and the assessment area (AA) consisting of the SA and an area of 200m around the SA which will not be directly impacted (Figure 11.1).

11.2 Environmental Legislation, Standards and Guidelines

Legislation, Standards and Guidelines relevant to the consideration of Cultural Heritage impact of the Project include the following:

¡ Antiquities and Monuments Ordinance;

¡ Environmental Impact Assessment Ordinance;

¡ Hong Kong Planning Standards and Guidelines;

¡ Technical Memorandum on Environmental Impact Assessment Process;

¡ Guidelines for Cultural Heritage Impact Assessment; and

¡ Development Bureau Technical Circular (Works) No. 06/2009: Heritage Impact Assessment Mechanism for Capital Works Projects.

11.2.1 Antiquities and Monuments Ordinance

The Antiquities and Monuments Ordinance (the Ordinance) provides the statutory framework to provide for the preservation of objects of historical, archaeological and paleontological interest. The Ordinance contains the statutory procedures for the Declaration of Monuments. The proposed monument can be any place, building, site or structure, which is considered to be of public interest by reason of its historical, archaeological or paleontological significance.

Under Section 6 and subject to sub-section (4) of the Ordinance, the following acts are prohibited in relation to certain monuments, except under permit:

¡ To excavate, carry on building works, plant or fell trees or deposit earth or refuse on or in a proposed monument or monument;

¡ To demolish, remove, obstruct, deface or interfere with a proposed monument or monument.

The discovery of an Antiquity, as defined in the Ordinance must be reported to the Antiquities Authority (the Authority), or a designated person. The Ordinance also provides that, the ownership of every relic discovered in Hong Kong after the commencement of this Ordinance shall vest in the Government from the moment of discovery. The Authority on behalf of the Government may disclaim ownership of the relic.

No archaeological excavation may be carried out by any person, other than the Authority and the designated person, without a licence issued by the Authority. A licence will only be issued if the Authority is satisfied that the applicant has sufficient scientific training or experience to enable him to carry out the excavation and search satisfactorily, is able to conduct, or arrange for, a proper scientific study of any antiquities discovered as a result of the excavation and search and has sufficient staff and financial support.

It should also be noted that the discovery of an antiquity under any circumstances must be reported to the authority, i.e. the Secretary for Development or designated person. The authority may require that the antiquity or supposed antiquity is identified to the authority and that any person who has discovered an antiquity or supposed antiquity should take all reasonable measures to protect it.

11.2.2 Environmental Impact Assessment Ordinance

The Environmental Impact Assessment Ordinance (EIAO) was implemented on 1 April 1998. Its purpose is to avoid, minimise and control the adverse impact on the environment of designated projects, through the application of the EIA process and the Environmental Permit (EP) system.

11.2.3 Hong Kong Planning Standards and Guidelines

Chapter 10 of the Hong Kong Planning Standards and Guidelines (HKPSG) details the planning principles for the conservation of natural landscape and habitats, historical buildings and archaeological sites. The document states that the retention of significant heritage features should be adopted through the creation of conservation zones within which uses should be restricted to ensure the sustainability of the heritage features. The guidelines state that the concept of conservation of heritage features, should not be restricted to individual structures, but should endeavour to embrace the setting of the feature or features in both urban and rural settings.

The guidelines also address the issue of the preparation of plans for the conservation of historical buildings, archaeological sites and other antiquities. It is noted that the existing Declared Monuments and Proposed Monuments and archaeological sites are listed in the explanatory notes of Statutory Town Plans and it is stated that prior consultation with the Antiquities and Monuments Office (AMO) is necessary for any development, redevelopment and rezoning proposals affecting the Monuments and archaeological sites and their surrounding environments.

It is also noted that planning intention for non-statutory town plans at the sub-regional level should include the protection of monuments, historical buildings, archaeological sites and other antiquities through the identification of such features on sub-regional layout plans. The appendices list the legislation and administrative controls for conservation, other conservation related measures in Hong Kong, and Government departments involved in conservation.

11.2.4 Technical Memorandum on Environmental Impact Assessment Process

The general criteria and guidelines for evaluating and assessing impacts to Sites of Cultural Heritage are listed in Annexes 10 and 19 of the Technical Memorandum on Environmental Impact Assessment Process (EIAO-TM). It is stated in Annex 10 that all adverse impacts to Sites of Cultural Heritage should be kept to an absolute minimum and that the general presumption of impact assessment should be in favour of the protection and conservation of all Sites of Cultural Heritage. Annex 19 provides the details of scope and methodology for undertaking Cultural Heritage Impact Assessment, including baseline study, impact assessment and mitigation measures.

11.2.5 Guidelines for Cultural Heritage Impact Assessment

This document, as issued by AMO, outlines the specific technical requirement for conducting terrestrial archaeological and built heritage impact assessments and is based upon the requirements of the EIAO-TM. It includes the parameters and scope for the Baseline Study, specifically desk-based research and field evaluation.

The prerequisite conditions for conducting impact assessment and mitigation measures are presented in detail, including the prediction and evaluation of impacts based upon five levels of significance (Beneficial, Acceptable, Acceptable with Mitigation Measures, Unacceptable and Undetermined). The guidelines also state that preservation in totality must be taken as the first priority and if this is not feasible due to site constraints or other factors, full justification must be provided.

Mitigation measures should be proposed in cases with identified impacts and shall have the aim of minimising the degree of adverse impact and also where applicable providing enhancement to a heritage site through means such as enhancement of the existing environment or improvement to accessibility of heritage sites. The responsibility for the implementation of any proposed mitigation measures must be clearly stated with details of when and where the measures will be implemented and by whom.

11.2.6 Development Bureau Technical Circular (Works) No. 06/2009: Heritage Impact Assessment Mechanism for Capital Works Projects

The Technical Circular provides the guidelines and procedures for assessing heritage impacts arising from the implementation of capital works projects. It is the responsibility of the works agent to confirm with AMO whether there are any “Heritage Sites” within or in the vicinity of the project boundary. A Heritage Impact Assessment (HIA) would be required if AMO decides that the heritage value of any” heritage site” in the vicinity of the project would be affected. The works agent must then submit a Study Brief and agree with AMO on the scope of the HIA. Once the HIA report has been completed it must be submitted to AMO for approval.

The guidelines also state that it is essential that every effort be made to minimise adverse impacts on heritage sites. For projects where the public interest is at stake and where adverse impacts cannot be entirely mitigated against, the project proponent and works agent should engage stakeholders and consult them on the proposed works at the earliest opportunity. It is the responsibility of the works agent to prepare options of project design, corresponding cost and other implications for the public to consider. As well the public engagement strategy should be tailored to meet the specific needs of each individual project. Finally, during the construction phase it is the responsibility of the works agent to ensure that the works and mitigation for heritage conservation are being carried out as stipulated in the HIA Report and approved by AMO.

11.3 Assessment Methodology

11.3.1 Archaeology

11.3.1.1 Baseline Study

As stated in the Guidelines for CHIA, the baseline study is used to compile a comprehensive inventory of all sites of archaeological interest within and in the environs of the Project AA. The results are then presented in a report that provides both clear evidence that the require processes have been satisfactorily completed as well as a detailed inventory of all identified sites of archaeological interest, which includes a full description of their cultural significance.

The following tasks are undertaken in order to gather the necessary information for the compilation of the baseline study:

Task 1: Desk-based Research

Firstly, desk-based research was carried out in order to identify any known or potential sites of archaeological interest within the Project AA and to evaluate the cultural significance of these sites once identified. The following is a non-exhaustive list of resources that are consulted as part of the research programme: the AMO published and unpublished papers and studies; publications on relevant historical, anthropological and other cultural studies; unpublished archival papers and records; collections and libraries of tertiary institutions; historical documents held in the Public Records Office, Lands Registry, District Lands Office, District Office and Museum of History; cartographic and pictorial documentation; and geotechnical information.

Task 2: Site Visit

To supplement the information gathered in the desk-based study, a site visit was undertaken to assess the current status of the AA and also to make note of existing impacts.

Task 3: Archaeological Field Investigation (if required)

If the results of the desk-based study and site visit indicate that there is insufficient data for purposes of identification of sites of archaeological interest, determination of cultural significance and assessment of impacts, an archaeological field investigation programme would be designed and submitted to the AMO for approval. Once approved, a qualified archaeologist must apply for a licence to undertake the archaeological excavation, which must be approved by the Antiquities Authority before issuance. The archaeological field investigation typically consists of some or all of the following steps:

Field Scan

If necessary, field walking would be conducted to identify archaeological deposits on the surface. The scanning of the surface for archaeological material would be conducted, under ideal circumstances, in a systematic manner and covers the entire AA. Particular attention is given to areas of land undisturbed in the recent past and to exposed areas such as riverbed cuts, erosion areas, terraces, etc. During the field scanning, concentrations of finds would be recorded, bagged and plotted on 1:1000 scale mapping and would be retained as part of the archive. Topography, surface conditions and existing impacts would be noted during the field walking.

Auger Testing Programme

If necessary, auger survey would be carried out within the AA in order to establish soil sequence, the presence/absence of cultural soils or deposits and their horizontal extent. The auger tool consists of a bucket, pole and handle and is vertically drilled by hand into the surface. When the bucket is filled with soil the auger is extracted and the soil emptied from the bucket. Soils are described and depth changes are measured inside the hole. The depth and type of any finds recovered are also recorded. The auger hole is abandoned when the water table, the end of the auger or rock is reached or the auger bucket fails to hold the soil. The location of each auger hole test is marked on a 1:1000 scale map. The results of the auger tests provide one of the criteria used to position the test pit excavations.

Test Pit Excavation

If necessary, test pit excavations would be carried out to verify the archaeological potential within the AA. The choice of location for test pit excavations would depend on various factors such as desk-based information, landforms, field scan and auger test results as well as issues relating to access.

Hand digging of test pits measuring between 1 by 1 and 2 by 2 metres would be carried out in order to determine the presence/absence of archaeological deposits and their stratigraphy. The size may depend on close proximity to large trees, narrow terraces or other external factors. Hand excavation would continue until decomposing rock or sterile soils are reached and no potential for further cultural layers exists. A test pit would also be abandoned when the effects of ground water prevent further excavation or when the depth poses safety problems.

During excavation contexts, finds and features would be recorded, soils would be described and relevant depths would be measured. Artefacts would be collected, bagged and labelled by context. Sections are photographed and drawn and, if required, ground plans would also be photographed and/or drawn. The position of each test pit, its top and bottom levels and associated TBM would be recorded by a qualified land surveyor and plotted on 1:1000 scale map. On completion of all recording test pits would be backfilled.

11.3.1.2 Reporting and Submission of Archive

A report of the findings of the archaeological survey, if required would be compiled following the requirements as outlined in the AMO’s Guidelines for Archaeological Reports. The processing of recovered archaeological material and preparation of the Project archive would follow the AMO’s Guidelines for Handling of Archaeological Finds and Archives.

11.3.1.3 Impact Assessment

The prediction and evaluation of both direct and indirect impacts must be undertaken to identify any potential adverse effects to all identified sites of archaeological interest within the Project AA. A detailed description of the works and all available plans (with their relationship to the identified resources clearly shown) would be included, to illustrate the nature and degree of potential impacts. The impact assessment must adhere to the detailed requirements of Annexes 10 and 19 of the EIAO-TM.

11.3.1.4 Mitigation Measures

As stated in the Guidelines for Cultural Heritage Impact Assessment “Preservation in totality must be taken as the first priority”. If such preservation is not feasible, as in the case where the need for a particular development could be shown to have benefits that outweigh the significance of the site of archaeological interest, a programme of mitigation measures must be designed and submitted to the AMO for approval. The mitigation measures must be clearly listed and the party responsible for implementation and timing of the measures must also be included. Examples of mitigation measures include; rescue excavation and archaeological watching brief.

11.3.2 Built Heritage

11.3.2.1 Desk-based Study

A desk-based study had been undertaken to determine the presence of built heritage resources in the Project AA. Information has been gathered from the following sources:

¡ List of Declared Monuments and Graded Buildings as issued by the AMO

¡ Published and unpublished papers and studies

¡ Publications on relevant historical, anthropological and other cultural studies

¡ Unpublished archival, papers, records; collections and libraries of tertiary institutions

¡ Historical documents which can be found in Public Records Office, Lands Registry, District Lands Office, District Office, Museum of History

¡ Cartographic and pictorial documentation and

¡ Previous Built Heritage Impact Assessment’s (BHIA) in the Project assessment areas

11.3.2.2 Built Heritage Field Survey

The purpose of the built heritage survey is to identify all built heritage resources within the survey boundary as defined in this proposal. The BHIA Survey must adhere to the above cited guidelines and provide adequate information to fulfil the relevant requirements as set out in Annexes 10 and 19 of the EIAO-TM.

The information gathered from the built heritage survey would be used to identify impacts and prepare mitigation recommendations (where necessary) for all of the resources identified in the survey. The built heritage survey report would be incorporated as part of the EIA Report for this Project.

11.3.2.3 Impact Assessment and Mitigation Recommendations

Prediction and identification of both direct and indirect impacts that may affect the built heritage resources within the Project assessment area would be undertaken. Preservation in-situ would always be the first priority for all heritage sites. If preservation in totality is not possible, mitigation would be proposed to minimise the degree of adverse impact to the greatest possible extent. As well, any disturbance to heritage sites that may cause physical damage should be avoided wherever possible through alteration of design, construction method or protective measures as appropriate.

11.4 Desk-based Study Findings

11.4.1 Archaeology

11.4.1.1 Geology and Topography

The geology of the SA consists of metasilt and sand stone and graphite schist and phyllite (Lok Ma Chau Formation) hillock. The wider AA (Figure 11.1) includes Pleistocene terraced alluvium which is located at the edges of ancient flood plain (Figure 11.2).

The hillock rises in the centre of the AA and is surrounded by two major streams and wet alluvial area which was capitalised on by turning it into ponds. Old maps show the streams on either side of the site area hill (1939; Figure 11.3). The stream to the west is no longer in existence (1957; Figure 11.4), although the area remains very wet; noticeable through the vegetation.

The SA hillock connects to the slopes and Kong Nga Po Road in the southwest and slopes gradually down to the north.

To the south of the AA, the narrow valley and steep hills water run-off is channelled into said ponds and add to the wet alluvial areas. The hills at the edges of the AA have been largely terraced and are of same solid geology as the SA.

11.4.1.2 Historical and Archaeological Background

There are no known historical villages within the SA or AA (for full details please refer to Section 11.4.2.2 below). There are also no known sites of archaeological interest within the SA or AA. A number of archaeological investigations however, have been conducted within the general closed border area; these are:

¡ The territory-wide archaeological survey of 1997-1998: Findings include Qing Dynasty to modern sherds near Pak Fu Shan, Tsung Yuen Ha, and Chuk Yuen.

¡ The 2000 Archaeological Survey & Assessment for Shenzhen River Regulation Project Stage III, HKIA 2001. Findings included a Song/ Yuan period site at Yuen Leng Chai; in addition Warring States-Han Dynasty geometric pottery surface finds were also collected at Yuen Leng Chai; finally, four early 20th century kilns at Muk Wu Nga Yiu area were recorded.

¡ The 2001 Archaeological Survey & Assessment for the Proposed NENT Landfill Extension, HKIA 2002. Findings included: An early 17th century to early 20th century settlement site was identified at Tong To Shan/ Lin Ma Hang area.

¡ Agreement No. CE20/2004 (EP), NENT Landfill Extension – Feasibility Study, CHIA AAL 2005. No archaeological deposits were recorded. However, cultural landscape features associated with the Tong To Shan Archaeological Site were identified and described.

¡ Northeast New Territories Village Sewerage Phase 2: Archaeological Monitoring Report, AAL 2006: Significant findings included the identification of a Ming Dynasty occupation at Tsung Yuen Ha. Other historical materials ranging from Song to Qing Dynasty were also collected from nearby historical villages, such as Tong Fong and Ping Che.

¡ Agreement No. PLNG 13/2007, Survey on Features with Cultural Heritage Value in the Sha Tau Kok, Ta Kwu Ling and Ma Tso Lung Areas, ERM 2007. This investigation consisted of Built Heritage survey without archaeological survey.

The historic findings mentioned above are indicative of use of the wider setting in past times and suggest geographical and topographical setting similar to the AA was used during the Song/Yuan, Ming and Qing Dynasties.

There is one investigation, which partially overlaps with the current AA and may provide insight into the archaeological potential of the AA:

Agreement No. CE60/2005(TP) Land Use Planning for the Closed Area – Feasibility Study Revised Preliminary Archaeological Survey Report, AAL 2010.

In this particular study, its study area covered an extended region including Area P3U2C1 which overlapped with our AA. P3U2C1 measured approximately 1280m² and includes a portion of the area along the road in the northeast, the flat area at the lower foothills of the SA and the area to the southwest of the SA (Figure 11.5). Only one test pit was conducted in Area P3U2C1 within government land deemed to have archaeological potential. The single test pit excavation indicated that topsoil overlies sterile and natural alluvial and colluvial soils. One sherd of modern white porcelain was recovered from the top soil. The report recommended that, for future purposes of archaeological impact assessment, the entirety of Area P3U2C1 should be considered to have little or no archaeological potential but the assessment conclusion does not highlight the need for further testing.

The Final report of the study: Agreement No. CE 60/2005(TP) Land Use Planning for the Closed Area- Feasibility Study Final Report provides a more general approach to the potential for archaeology in the Closed Border area. It states that the future project proponent shall consult with the AMO to confirm if an archaeological impact assessment is required within the Man Kam To development corridor (which partially corresponds with current Assessment Area), recreation area at Pak Fu Shan, Fung Wong Wu, Tong To Ping Tsuen. For the building project within village zones of Chow Tin Tsuen, Muk Wu Tsuen, Liu Pok, Tong Fong and Tsung Yuen Ha, archaeological investigation of building sites in areas of archaeological potential are recommended; these should be conducted with the owners' permission prior to village house construction.

11.4.1.3 Existing Impacts

Field visits were conducted in March and May 2012 to find out the existing archaeological impacts. For the purpose of describing archaeological findings and the existing impact assessment, the AA was divided into six sections as shown in Figure 11.6.

Section 1 - Topography: Elevation between 38.5mPD on top and sloping down to 20 to 26mPD

Section 1 covers the project SA which will be impacted, namely the Sha Ling Livestock Waste Control Centre and the slopes of the hillock on which it sits. No access was gained to the centre but the view for the entrance gate indicated that concrete surface covering and buildings occupy the site (Figure 11.7). In addition, aerial photograph taken in 1990 shows about the formation works conducted for the Sha Ling Livestock Waste Control Centre (Figure 11.15).

Utility maps indicated that there were CLP cables along the slopes of the hill and the topographical map indicate that a large portion of the slopes to the south and the slopes along the northeast of the hill have been cut. A local informant reported this was carried out around 20 years ago by the Government.

The 1914 map (Library ref: HF-2) and 1924 aerial photograph (ref: H8/7, taken at a height of 3,500’) shows a path linking to San Uk Ling traverses the top of the hill but no other occupation impact. In fact, aerial photography and old maps indicated that the top of the SA was unoccupied until the 1990’s.

Section 2 – Topography: Elevation between 10 to 12mPD in the flat and pond area and slope upwards from the road up to around 40mPD

Section 2 covers mainly the area along the road extending from Man Kam To Road to Kong Nga Po. Part of this section was tested during the 2009 investigation (AAL 2010) (Figure 11.5). Some residential houses are located along the road (Figure 11.8) and at least one new house was built since 2009. The houses along the road to the east of the SA did not appear until 1973 (Figure 11.9), prior to this date a single house was located on the hill slope of Mong Fui Ling and a few isolated buildings marked Chung Pui which was visible on the 1939 map (HB5-10; Figure 11.3) within the alluvial area.

Utilities within Section 2 include PCCW cables and water supply pipes which run along the road right up to the San Uk Ling Holding Centre.

Section 3 - Topography: Elevation between 12 to 15mPD in the flat and pond area and sloping from the road towards the south up to 60mPD.

San Uk Ling Holding Centre, a migrant detention centre, is located within this section. The compound is secured and inaccessible. To the rear of the Centre is bordered by the Firing Range while in front graves occupy the slope (Figure 11.10).

Om Shan lower slopes lie to the south of the Centre. The lower slopes are occupied by graves and urns. Recently the slopes have been prepared for a small orchard. Some very limited digging had occurred within the orchard area to plant young trees; it was within the spoil of these that the pottery was noticed. Song Dynasty pottery sherds (see Figure 11.11) were collected from the surface in Section 3 (Figure 11.12). This area is only accessible through a gate which was locked during the second field visit.

Majority of existing ponds are located to the east of the SA and lie within this section. The rear of the section (to its southwest) consists of a channelled stream, some cut slope and rocky natural slopes.

Section 4 - Topography: Elevation around 17mPD and ascending slightly to the north to 22mPD

Section 4 consists of residential and light industrial buildings and open spaces and are located to the north of the SA. The residential and industrial space is occupied, fenced and covered in concrete surfacing. Utilities impacts in the area are relatively minimal and consist of PCCW cables and water supply pipes.

The section also includes a small raised area with some graves and structures to the far north of the section (Section 4A). The raised area has been terraced and was relatively recently converted to nursery with small trees (Figure 11.13 – Section 4A).

The south of the section was used as agricultural fields for a long time, but according to aerial photographs buildings occupy the area in 1973 (Figure 11.9).

Section 5 - Topography: Elevation between 34 to 37mPD

The background history of this section is not entirely clear. The area immediately to its north and south consists of cut slopes and the topographical map does not show any contour lines for this section, while the 1957 topographical map (Figure 11.4) suggests this area would have been part of hills sloping towards the north. In the field the area appears to be man-made woodland (Figure 11.14) and the unnatural elevation of this area indicates modification of original topography. A 1990 aerial photograph (Figure 11.17) shows major earthworks occur not only within the SA but also within Section 5 (Figure 11.15).

Section 6 - Topography: Elevation between 13m to 20mPD

This section largely consists of wet abandoned agricultural fields covered in ginger flowers and other vegetation which indicates wet environment; (former) ponds are shown on the topographical map (Figure 11.6). The major stream shown on early maps (see Figure 11.3 – 1939) has largely vanished, but area is still very wet. A few temporary and residential structures are located to the south of the section but overall the area is unoccupied (Figure 11.16). Utilities to a few residential houses on the lower hill slope include PCCW cables, water supply and street lighting along the road.

In general within the sections, there are no impacts arising from drainage, town gas pipes, New World telecom alignments, television cables or Hutchinson Global telecommunication cables (information supplied by utilities companies for full reference see Section 11.4.1.4).

11.4.1.4 Bibliography and references

AAL 2005. Agreement No. CE20/2004 (EP), NENT Landfill Extension – Feasibility Study. Cultural Heritage Impact Assessment. Unpublished.

AAL 2006. Northeast New Territories Village Sewerage Phase 2: Archaeological Monitoring Report: Unpublished.

AAL 2010 for Planning Department, Agreement No. CE60/2005 (TP) Land Use Planning for the Closed Area – Feasibility Study –Revised Preliminary Archaeological Survey Report. Unpublished.

AMO 1997-1998. Territory-wide Survey: Northeast Section. Unpublished.

ERM 2007, Agreement No. PLNG 13/2007 Survey on Features with Cultural Heritage Value in the Sha Tau Kok, Ta Kwu Ling and Ma Tso Lung Areas (28 September 2007) ERM/ Planning Department. Unpublished.

HKIA 2001. The 2000 Archaeological Survey & Assessment for Shenzhen River Regulation Project Stage III. Unpublished.

HKIA 2002. The 2001 Archaeological Survey & Assessment for the Proposed NENT Landfill Extension. Unpublished.

Planning Department 2010. Agreement No. CE 60/2005(TP) Land Use Planning for the Closed Area- Feasibility Study Final Report.

Maps and aerial photographs consulted:

¡ Hong Kong Geological map sheet 3 HGM20, edition 1991

¡ 1939 Topographical map, HK Central Library reference HB 5-10; scale eight inches to a mile

¡ 1957 Topographical map, HK Central Library reference L881, Sheet 10; scale 1:20,000

¡ Aerial photograph of 1990; Lands Department Aerial Photo Ref: A22480; taken from 2000'

¡ Aerial photograph of 1973; Lands Department Aerial Photo Ref. 7883, taken at 12,500’

¡ 1914 Topographical map; HK Central Library reference HF-2, 5, 2 inches to mile.

¡ Aerial photograph of 1924; Lands Department Aerial Photo Ref:H8/7; taken from 3,500’

¡ Aerial photograph of 2007; Lands Department Aerial Photo Ref: CW77882, taken at 3000’

Utilities information:

¡ 20120117 PCCW Plant Info;

¡ 20120201 DSD No existing or planned facilities;

¡ 20120201 HKBN No utilities;

¡ 20120203 WSD Existing Water Supply Utilities;

¡ 20120209 CLP Existing utilities;

¡ 20120213 Towngas No existing pipeline;

¡ 20120222 New World Telecom No utilities;

¡ 20120224 Cable TV No utilities;

¡ 20120307 Hutchison No plant; Street lighting

AMO Website

11.4.2 Built Heritage

11.4.2.1 Results of Previous Investigations

Agreement No. CE60/2005 (TP) Land Use Planning for the Closed Area – Feasibility Study – Strategic Environmental Assessment Study (Final Report 2010)

The study scope for the Project included improvements to Man Kam To Road and an initial site visit was undertaken to parts of the current Project AA along Man Kam To Road. A Tin Hau Temple was identified and it was also noted in the report that this area contained scattered graves and BHIA would be required as part of future studies.

11.4.2.2 Historical Background of the Project Site Area

The Project SA does not contain any historical villages. The nearest historical village is San Uk Ling located to the north. This village of the Cheung Clan (originally from Wong Pui Ling in Shenzhen) has a history probably dating back some 300 years (ERM 2007). The other major feature in the vicinity of the SA is the Sandy Ridge Cemetery, which was opened in 1949.

An aerial photograph of the SA from 1990 (Figure 11.17) shows the Project SA was cleared for the construction of the Sha Ling Livestock Waste Control Centre. The 200 m assessment area around the facility boundary can be seen to be mostly rural with ponds, open areas and scattered buildings. The locations of the six historic clan graves and Tin Hau temple are also marked on Figure 11.17.

A more recent aerial photograph, taken in 2007 (Figure 11.18) shows that the SA has not changed significantly since 1990 (Figure 11.17). The main changes are that there is less land under cultivation and there are more wooded areas than was previously. For comparative purposes, the identified heritage resources have also been marked on Figure 11.18.

11.4.2.3 Declared Monuments

There are no Proposed or Declared Monuments in the Project AA.

11.4.2.4 Graded Historic Buildings

There are no Graded Historic Buildings in the Project AA.

11.4.2.5 Government Historic Sites Identified by AMO

There are no such sites in the Project AA.

11.4.2.6 Results of the Built Heritage Field Survey

As the presence of graves and a Tin Hau Temple was noted in the desk-based study, a built heritage field survey was undertaken to identify historic clan graves in the project AA. The study boundary for the project is defined as 200 m from the proposed project site. As a result of the survey six historic clan graves and the above mentioned Tin Hau Temple were recorded. No other built heritage items were found to be located within the 200 m boundary. The catalogue containing written and photographic information of the historic clan graves and the Tin Hau Temple is provided in Appendix 11.1. A Map showing the locations of the historic clan graves and the Tin Hau Temple with their relationship to the SA is shown in Figure 11.19. 1:1000 scale maps of the built heritage resources are shown in Figures 11.20, 11.21 and 11.22.

11.5 Identification of Environmental Impact

11.5.1 Archaeology

The AA has no known sites of archaeological interest, the limited archaeological investigations that have been conducted within the closed border area however, have shown that Song, Ming and Qing Dynasty deposits could occur in the current AA, based on geographical, geological and topographical similarities. Limited archaeological investigation conducted within the AA concluded that the area around the hilllock to the north- northeast has little to no archaeological potential. A local informant confirmed that extensive fishponds used to surround the hillock. Despite the negative desk-based findings, the field visit indicated that pockets of ancient settlement evidence may exist.

Table 11.1 summarises the findings of the desk-based review and field visit and provides an assessment of each section’s archaeological potential.

Table 11.1 Archaeological potential for each section:

Section	Description	Assessment	Summary
1	Top of hill with impacts consisting of levelling, building construction and paving.	No potential due to the existing impacts; site formation impacts show that the top of the hillock was previously levelled. This action would have removed any potential for archaeological deposits. Utilities include CLP gas pipes, electricity cables and outdoor light posts. These would have had additional adverse impact on subsurface deposits, if present.	No archaeological potential.
2	Section 2 is situated around existing road and is occupied by houses and associated landscaping of surrounding garden areas. Known impacts due to ponds and low-lying area and construction.	This section is deemed to have very low to no archaeological potential due to the results of the previous investigation and known impacts. Utilities consist of street lighting, PCCW and electricity cables, and water mains. These would have had additional adverse impact on subsurface deposits, if present.	No archaeological potential.
3	Section 3 largely occupied by known impacts such as ponds, San Uk Ling Holding Centre and channelled stream to the southwest however, Song Dynasty sherds found during the field visit highlight the potential of the lower slopes of Om Shan.	Known archaeological potential of lower slopes of Om Shan through surface finds. Access limitations due to private area and graves.	Some archaeological potential.
4	Section 4 consists of residential and light industrial area with major construction impacts.	Major construction impacts and inaccessible due to residential area and temporary structure. Utilities in the area include: PCCW and electricity cables, water supply pipes, CLP alignments and some street lighting. These would have had additional adverse impact on subsurface deposits, if present..	Very low archaeological potential.
4A	Raised area at the north of Section 4 which has been terraced and small trees have been planted.	Due to no previous investigation and limited visual impacts of the raised area in the northern part of section 4, some potential may exist. Access limitation due to private area and graves	Very low archaeological potential
5	Section 5 is a wooded area located immediately south of the SA.	Extensive landscaping, including major earth and slope works has adversely impacted the archaeological potential of this area.	No archaeological potential.
6	Section 6 is very wet with few temporary structures.	The topographical level, presence of ponds and abundance of ginger flowers which favour wet conditions, indicate that the area is low-lying. The ponds are artificially excavated areas which adversely impacted the original landscape, while the low-lying nature of the area does not favour occupation or settlement. Utilities are located along the road only and include street lights, water mains, PCCW and electricity cables and CLP alignments. These would have had additional adverse impact on subsurface deposits, if present.	No archaeological potential.

Assessment of the types of potential impacts: direct, indirect, cumulative and residual is as follows:

Direct impacts on archaeological resources occur during the construction phase when subsurface works affect potential or identified deposits. There are no direct impacts arising from the proposed development on buried sites of archaeological interest as the SA is deemed to have no archaeological potential. Similarly, there will be no impacts arising from the operational phase of the proposed development.

No indirect impacts are expected from the proposed development as the areas of potential or archaeological interest are not in the immediate vicinity of the proposed works and will not be affected by the proposed works even if the boundary is slightly modified. Direct impact on Section 3 can only occur if there is a major change of the works area.

Two projects, namely Upgrading of existing Man Kam To Road identified in CE 60/2005 (TP) Land use Planning for the Closed Area – Feasibility Study and CE 16/2012 (CE) Engineering Feasibility Study for Kong Nga Po may be considered for cumulative impacts. There are however, no areas of archaeological interest identified in the vicinity of the existing road near the SA or the area near Section 5 and no cumulative impacts are expected.

There will be no residual impacts on archaeological resources arising as the proposed development requires no mitigation.

11.5.2 Built Heritage

11.5.2.1 Construction Phase

The proposed works within the Project SA have the potential to indirectly impact the built heritage resources in the surrounding AA through ground borne vibration.

11.5.2.2 Operation Phase

No impacts from the operation of OWTF 2 have been identified with respect to built heritage resources.

11.6 Prediction of Environmental Impact

11.6.1 Archaeology

There are no known sites of archaeological interest within the SA or AA. Based on the desk-based review and field visit one area within the AA was identified as having some archaeological potential. This area has confirmed archaeological potential due to the chance finding of three Song dynasty sherds. The predicted impacts during construction and operational phases are identified below.

11.6.1.1 Construction Phase

No area of archaeological interest would be directly impacted by the proposed works of OWTF 2 (Figure 11.23). Therefore no further archaeological field works are recommended. If however, associated works within Section 3 are designed for in the detailed design phase, an archaeological investigation would be required prior to the commencement of works. Please note that there are currently no associated works designed within Section 3.

The following scope and methodology of archaeological investigation is recommended for AMO's consideration if works would be occurred within the potential area of archaeological interest as marked on Figure 11.23.

Section 3: Archaeological investigation of the lower slopes of Om Shan, including field scan of the entire area, auger hole tests where appropriate and a minimum of five test pit excavations should be carried out. The proposed investigation area is marked on Figure 11.23. Access to the land may be an issue as the lower slopes are currently in private use and have graves and urns on them. Access is gained through a metal gate.

11.6.1.2 Operation phase

There will be no additional impacts on archaeological resources during the operation phase.

11.6.2 Built Heritage

11.6.2.1 Construction Phase

The Project SA was completely cleared for the construction of the Sha Ling Livestock Waste Control Centre and there is no potential for built heritage resources to be present. The 200 metre assessment area, however, has been found to contain seven built heritage resources, based on the desk-based study and site visit. These resources have the potential to be indirectly impacted by the proposed construction works within the SA.

11.6.2.2 Operation Phase

There will be no additional impacts on built heritage resources during the operation phase.

11.7 Evaluation of Environmental Impact

11.7.1 Archaeology

There will be no impacts on sites of archaeological interest and potential areas of archaeological interest arising from the proposed Project. If, however, associated works would be proposed within potential area of archaeological interest of Section 3 within the AA in the detailed design phase, an archaeological investigation would be required. The scope and methodology of archaeological investigation are recommended in Section 11.6.1.1 for AMO's consideration.

11.7.2 Built Heritage

11.7.2.1 Construction Phase

The resources as listed in Table 11.2 have the potential to be indirectly impacted by the proposed construction works within the SA through ground borne vibration and contact with machinery and equipment during the construction works.

Table 11.2 Evaluation of Impacts to Built Heritage Resources

Resource	Distance to Proposed Works Site (metre)	Impact Assessment
Grave G1	190	Based on the distance to the works site no impact is expected to arise from the construction works.
Grave G2	165	Based on the distance to the works site no impact is expected to arise from the construction works.
Grave G3	178	Based on the distance to the works site no impact is expected to arise from the construction works.
Grave G4	190	Based on the distance to the works site no impact is expected to arise from the construction works.
Grave G5	60	Based on the distance to the works site no impact is expected to arise from the construction works.
Grave G6	15	The grave was renovated in 1984 and consists of modern concrete material. No historical elements were identified during the survey. The 15 m distance to the project site is considered sufficient buffer zone and no significant adverse impacts are expected.
Tin Hau Temple (BH-1)	170	Based on the distance to the works site no impact is expected to arise from the construction works.

11.7.2.2 Operation Phase

There are no identified impacts during the operation phase to built heritage resources.

11.8 Mitigation of Adverse Environmental Impact

11.8.1 Archaeology

The SA is evaluated as having no archaeological potential, and therefore, no mitigation measures are recommended. If, however, associated works would be proposed within potential area of archaeological interest of Section 3 within the AA in the detailed design phase, an archaeological investigation would be required prior to the commencement of works. The scope and methodology of archaeological investigation are recommended in Section 11.6.1.1 for AMO's consideration.

The proposed development will only affect SA and thus the archaeological review concludes that no known Sites of Archaeological Interest will be impacted by the proposed Project and no archaeological potential area is identified within the proposed works area and no mitigation will be required.

It has to be noted however that if antiquities or supposed antiquities are discovered in the course of excavation works, the project proponent must arrange a temporary suspension of works in the affected area and notify AMO immediately of the discovery. Course for further action should be agreed with AMO prior to continuation of the works. Sufficient resource as well as time for conducting necessary archaeological works should be provided by the project proponent if so required.

11.8.2 Built Heritage

No mitigation would be required during the construction or operation phases for built heritage resources.

11.9 Evaluation of Residual Impact

There would be no residual impacts on archaeological and built heritage resources arising from OWTF 2.

11.10 Environmental Monitoring and Audit

11.10.1 Archaeology

No EM&A requirements are considered necessary during the construction and operation phases of the proposed works as there are no impacts on known sites of archaeological interest and potential areas of archaeological interest.

11.10.2 Built Heritage

No EM&A requirements are considered necessary during the construction or operation phases of the Project.

11.11 Conclusion

11.11.1 Archaeology

The desk-based review identified that the proposed SA has no archaeological potential. Some archaeological potential exists in the wider AA, but these areas with archaeological potential would not be impacted by the proposed OWTF2. If, however, associated works would be proposed within potential area of archaeological interest of Section 3 within the AA in the detailed design phase, an archaeological investigation would be required prior to commencement of works. The scope and methodology of archaeological investigation are recommended but need to be agreed with AMO prior to implementation.

At this stage there is no need for mitigation as no impacts are expected.

11.11.2 Built Heritage

No mitigation measures have been identified to be necessary for built heritage resources during the construction and operation phases in the Built Heritage Impact Assessment. The construction and operation of the proposed OWTF 2 will not cause any insurmountable adverse impacts and no cumulative impacts will occur as a result of this Project.