15       Conclusion.. 15-1

15.1   General 15-1

15.2   Air Quality Impact 15-1

15.3   Noise Impact 15-2

15.4   Water Quality. 15-4

15.5   Sewage and Sewerage Treatment Implications. 15-4

15.6   Waste Management 15-4

15.7   Land Contamination. 15-6

15.8   Ecology Impact 15-7

15.9   Fisheries Impact 15-7

15.10 Landscape and Visual Impacts. 15-8

15.11 Cultural Heritage. 15-8

15.12 Environmental Monitoring and Audit Requirements. 15-9


15                       Conclusion

15.1                 General

15.1.1            An EIA Report has been prepared for the partial development of Fanling Golf Course Site in accordance with the requirements given in the EIA Study Brief (ESB-318/2019) and the EIAO-TM. Environmental assessment of the potential environmental impacts associated with the construction and operation of the Project has been conducted. Environmental issues covered in the EIA include:

·       Air quality impact;

·       Noise impact;

·       Water quality impact;

·       Sewerage and sewage treatment implications;

·       Waste management implications;

·       Land contamination;

·       Ecology impact;

·       Fisheries impact

·       Landscape and visual impacts; and

·       Impact of Cultural heritage.

15.1.2            This section summarizes the assessment results of each technical aspect and concludes the acceptability of the overall environmental performance of the Project.

15.1.3            The key assessment assumptions, limitation of assessment methodologies and all related prior agreements with EPD on assessment of different environmental aspects are given in Appendix 15.1.

15.1.4            A summary of environmental impacts identified in this EIA is provided in Appendix 15.2 and the conclusions of technical chapters are described in the following sections.

15.2                 Air Quality Impact

Construction Phase Impact

15.2.1            Potential air quality impacts from the construction works of the Project would mainly be related to construction dust from excavation, materials handling, spoil disposal and wind erosion. Quantitative fugitive dust assessments have been conducted including the cumulative impact caused by nearby concurrent construction works within the assessment area. With the implementation of mitigation measures as stipulated in the Air Pollution Control (Construction Dust) Regulation, dust suppression such as hourly watering at the active works areas, exposed areas and unpaved haul roads, erection of 3m hoarding along site boundary and good site practices, and environmental monitoring and audit (EM&A) programme, the predicted Total Suspended Solid (TSP), Respiratory Suspended Solid (PM10) and Fine Suspended Solid (PM2.5) at representative Air Sensitive Receivers (ASRs) would comply with the criteria stipulated in the Air Quality Objectives (AQOs) and EIAO-TM.

Operation Phase Impact

15.2.2            Quantitative assessment has been conducted taking into account the key existing and planned/committed air pollution sources during operation phase including the vehicular emissions from open sections of existing roads, existing and proposed Public Transport Interchanges (PTIs), proposed carpark and proposed road/junction improvements within the assessment area. Key representative air pollutants include Nitrogen Dioxide (NO2), PM10 and PM2.5. The assessment results concluded that the predicted cumulative air quality impacts with full population intake on all ASRs would comply with the AQOs. Therefore, no adverse residual air quality impact during operation phase is anticipated.

15.3                 Noise Impact

Construction Noise Impact

15.3.1            Construction noise associated with the use of PME for different stages of construction has been conducted. With the implementation of quieter construction method and practical mitigation measures including good site management practices, use of QPME, use of movable noise barrier, and noise enclosure, construction noise impacts at all of the neighbouring residential noise sensitive uses and educational institutions during normal school period would be controlled to acceptable levels. Minimum separation distance between schools and critical works area during school examination period have been recommended to mitigate potential adverse construction noise impact during examination period. With the recommended mitigation measures in place, construction noise impacts on all representative NSRs would comply with the relevant criteria. In case of any construction activities during restricted hours, it is the Contractor’s responsibility to ensure compliance with the Noise Control Ordinance (NCO) and the relevant TMs. The Contractor will be required to submit a construction noise permit (CNP) application to the Noise Control Authority and abide by any conditions stated in the CNP, should one be issued. It should be noted that description made in this report does not guarantee that a CNP will be granted for the project construction. The Noise Control Authority would take into account the contemporary conditions of adjoining land uses and other considerations when processing the CNP application based on the NCO and relevant TM issued under the NCO. The findings in the report shall not bind the Noise Control Authority in making the decision.

Road Traffic Noise Impact

15.3.2            Operation road traffic noise impact on the representative existing and planned noise sensitive uses within and near the PDA and the road modification works have been predicted.  To mitigate the road traffic noise impact on the existing and planned NSRs within and near the PDA and near the road modification works, a combination of noise mitigation measures have been recommended, including i) application of low noise road surfacing material along some sections of Project roads (e.g. Po Kin Road and Ping Kong Road) and other roads, ii) provision of acoustic window (baffle type) at planned residential blocks, iii) provision of Class Assessment Approach at the proposed school, iv) restriction on locating the more noise sensitive welfare uses at façade facing Ping Kong Road. With the implementation of mitigation measures, the predicted traffic noise levels of the existing NSRs and planned NSRs would comply with the relevant noise criteria. Residual impact on representative existing and planned NSRs is not expected.

Fixed Noise Source Impact

15.3.3            Fixed noise source impact assessment has been conducted for all existing and planned fixed noise sources.  Noise impact from planned fixed noise source under this Project (i.e. ventilation fans for the proposed PTI) could be effectively mitigated by implementing noise mitigation measure at source. With the adoption of the proposed maximum allowable SWL, the predicted noise level at the representative NSRs would comply with the relevant noise criteria for both existing and planned fixed noise sources.

15.3.4            The PTI will be enclosed and designed to avoid direct line-of-sight to the NSRs.  Canopy at the ingress and egress will also be provided.  Therefore, adverse fixed noise sources impact on the NSRs is not anticipated.  The design of the PTI and the proposed maximum allowable SWLs of the ventilation fans shall be reviewed with the final design during the detailed design stage.

Aircraft Noise Impact

15.3.5            Aircraft noise impact on planned sensitive uses within Sub-area 1 of PDA have been reviewed. The NEF 25 Contour have taken into account various parameters including all flight path(s) to be in use under 3RS operation. All departure flight path(s) to be in use under the 3RS operations and near to the development site(s) have been assessed. As confirmed by AAHK, the NEF 25 Contour is up-to-date. The Project area is located at over 15km from the NEF 25 Contour of the HKIA under the 3RS operation. Adverse aircraft noise impact due to 3RS operation is not anticipated.

15.3.6            The aircraft noise impact from the operation of Shek Kong Airfield have been reviewed. The separation between the PDA and the Shek Kong Airfield is approximately 5.3 km. In view of the large separation between PDA and Shek Kong Airfield, adverse aircraft noise impact due to operation of Shek Kong Airfield is not anticipated. According to the latest information, the approach and departure operation of aircrafts would maintain sufficient separation distance from the PDA. Therefore, no adverse aircraft noise impact is anticipated in PDA.

Helicopter Noise Impact

15.3.7            Helicopter noise impact on planned sensitive uses within Sub-area 1 of PDA have been reviewed. According to the latest information, the flight path of helicopters would maintain sufficient separation distance from noise sensitive receivers in Sub-area 1 of PDA. Therefore, no adverse helicopter noise impact is anticipated in PDA.

15.4                 Water Quality

Construction Phase

15.4.1            Minimization of water quality deterioration could be achieved through implementing the appropriate mitigation measures. Regular site inspections should be undertaken routinely to inspect the construction activities and works areas in order to ensure the recommended mitigation measures are properly implemented.

Operation Phase

15.4.2            The key potential source of impact on water quality during the operation phase of the Project would include the road run-off, storm run-off from building, sewage and wastewater effluents and usage of agrochemicals.  Mitigation measures with adequate maintenance are recommended to remove grits and grease from the runoff during operation. All sewage and wastewater generated from these facilities would be properly collected and diverted to public sewer. In addition, a management plan stating the details of application of agrochemicals including the type, dosage, frequency, application instructions shall be prepared.     No adverse operation phase impact is anticipated.

15.4.3            There would be no residual water quality impact during both construction and operation phases of the Project.

15.5                 Sewage and Sewerage Treatment Implications

15.5.1            The proposed sewerage will collect sewage from the public housing site and convey to the downstream sewerage system.  During construction phase, substantial impact on the existing sewerage system arising from the Project is not anticipated.

15.5.2            New public sewerage system is proposed in the PDA to collect the sewage generated from the proposed development in the PDA to Shek Wu Hui Sewage Treatment Works (SWHSTW).  Based on the findings of the sewerage and sewage treatment impact assessment, EPD advised that SWHSTW has adequate treatment capacity to cater for the sewage flow generated from the proposed housing development upon upgrading works.

15.6                 Waste Management

Construction Phase

15.6.1            The main waste types to be generated during the construction phase of the Project would include inert and non-inert construction and demolition (C&D) materials, chemical waste, asbestos-containing materials (ACMs) and general refuse. Reduction measures have been recommended to minimise the amount of materials generated by the Project by reusing C&D materials as far as practicable before off-site disposal.

15.6.2            An estimated total of 950,000 m3 of C&D materials are expected to be generated, of which 620,000 m3 are inert C&D materials and 330,000 m3 are non-inert C&D materials. Out of the non-inert C&D materials (clean soil) 56,000 m3 is expected to be reused on-site. 50,000 m3 of inert C&D materials are expected to reuse on-site and 570,000 m3 is estimated to be disposed of at the Public Fill Reception Facility (Tuen Mun Area 38 Fill Bank), whereas 66,000 m3 of non-inert C&D materials shall be recycled prior to off-site disposal and 208,000 m3 of non-inert C&D materials shall be disposed of at designated landfill (NENT).

15.6.3            A C&DMMP is required as the estimated quantity of C&D materials to be generated is over 50,000 m3, and according to Section 4.1.3 of the PAH, the proposed Project is not classified as “designated” projects under Schedule 2 of the EIAO but is generating surplus C&D materials in excess of 300,000 m3 – the C&DMMP shall be submitted to PFC in principal approval prior to commencement of the detailed design stage. The C&DMMP should be vetted and endorsed by the departmental Vetting Committee before submitting it to PFC for approval. As such, the C&DMMP shall be available in a later stage.

15.6.4            During construction phase, chemical waste generated shall be collected by a licenced chemical waste collector and to be disposed of at a licenced chemical waste treatment and disposal facility – the Chemical Waste Treatment Centre (CWTC). The chemical waste shall be handled in accordance with the Code of Practice on the Packaging, Labelling and Storage of Chemical Waste published by the EPD.

15.6.5            All asbestos-containing materials (ACMs), if confirmed to be present within the existing premises, must be removed in accordance with the Air Pollution Control Ordinance and prior to the demolition work. The amount of asbestos wastes generated shall be confirmed upon results from the Asbestos Investigation Report. The removal and disposal of asbestos wastes are to be conducted by a licensed waste collector in compliance with the Waste Disposal Ordinance.

15.6.6            Construction waste is suggested to be on-site recycled and reused as much as possible. Various waste management measures and good site practices also provided to reduce the volume of waste. Provided that the waste is managed by implementing all the recommended measures, no unacceptable adverse environmental impacts arising from the handling, storage, transportation or disposal of the waste generated by the Project would be envisaged.

Operation Phase

15.6.7            The main types of waste to be generated during the operation phase of the Project would consist of general refuse, clinical and chemical wastes.

15.6.8            The estimated volume of waste generation in the operation phase is approximately 34 tpd of general refuse, of which 6.5 tpd would be recycled with the remaining 27.5 tpd for final disposal at landfills. Mitigation measures must be implemented for the identified types of waste in order to minimise the potential adverse impacts to the environment. During operation, general refuse should be collected on a daily basis and delivered to the refuse collection point accordingly. A reputable waste collector shall be employed to remove general refuse regularly to avoid odour nuisance or pest/vermin problems. Sufficient recycling containers are recommended to be provided at suitable locations to encourage recycling of waste such as aluminum cans, plastics bottles and wastepaper.

15.6.9            Clinical waste would be generated from the welfare facilities during operation phase and they shall be properly separated from other wastes, packed, labelled, centrally collected and stored in designated clinical waste storage rooms. Clinical waste shall be collected by licensed clinical waste collectors for disposal at the licensed disposal facility. It is the responsibility of the management of welfare facilities to find the list of licensed waste collectors (as provided on EPD’s website) and implement adequate clinical waste collection at regular intervals.

15.6.10         Chemical waste shall be handled and disposal of according to the measures stipulated in the Waste Disposal (Chemical Waste) (General) Regulation, and the Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes shall also be observed. Chemical wastes shall be collected periodically in drum-type containers and disposed of at CWTC at Tsing Yi by licensed chemical waste collectors.

15.1.1              With the proper handling and implementation of recommended mitigation measures for the handling, transportation and disposal of the wastes generated from Project activities, adverse residual waste management implications are not anticipated for both the construction and operational phases.

15.7                 Land Contamination

15.7.1            This land contamination assessment examined the potential land contamination impacts at the Proposed Development Area (Sub-Areas 1 to 4), and the associated off-site works area. The land contamination assessment consisted of detailed desktop reviews, site inspections, the proposed site investigation and their potential impacts to land users during construction and operation phases.

15.7.2            The land contamination assessment follows a risk-based screening approach to the investigation of contaminated land, in order to identify any past or present potentially contaminating activities and to provide the assessment of the extent and nature of site contamination if it exists.

15.7.3            If the levels of contamination need to be remediated for the development area to be suitable for the intended land use, remediation objective of rural and urban residential (whichever more stringent) at Sub-Area 1 and Sub-Area 2 (partial), and public parks classifications at Sub-Area 2 to Sub-Area 4 will be adopted to ensure the contaminants will not pose an unacceptable risk to human health or to the environment.

15.7.4            Sampling strategy with details on representative sampling and analysis for determination of the nature and extent of the actual contamination conditions of soil and/or groundwater at the PDA are proposed in the given CAP (Appendix 8.1). Given the PDA is still in operation, SI is unlikely to be carried out at this stage and shall only begin after the land has been reverted to Government  in 2023. Upon the land has been reverted to Government and site clearance, a re-appraisal and a supplementary CAP, incorporation of findings of covering the entire assessment area and updated sampling and testing strategy, shall be prepared and submitted to EPD for approval. Site investigation and lab analyses shall commence after the approval of the supplementary CAP by EPD.

15.7.5            Following the completion of SI works, the SI results should be presented in the Contamination Assessment Report (CAR) for submission to EPD, and if remediation is required, Remediation Action Plan (RAP) shall be prepared with the purpose to set remediation goals and specify remediation monitoring and measurements to monitor remediation progress. The RAP shall be submitted to EPD for approval before the commencement of remediation works.

15.7.6            A Remediation Report (RR) shall be prepared for submission to EPD to demonstrate adequate remediation works have been completed to meet the relevant remediation goals. The content of the RR shall include the description of remediation programme carried out and the remediation monitoring results. The RR shall be submitted to EPD for endorsement. No construction works or development of site should be carried out prior to the endorsement of the RR.

15.7.7            Upon obtaining site investigation results, if high level of naturally-occurring arsenic is found present within the Project area and any associated off-site works area, a health impact assessment shall be conducted following the requirement listed in Clause of the EIA Study Brief and based on established international practices, including any codes of practices and guidelines applicable to Hong Kong with suitable reference to the approved EIA report of North East New Territories New Development Areas (Register no.: AEIAR-175/2013).

15.7.8            Such consideration of mitigation measures with justifications on the scope, approach and methodology to be adopted in the health impact assessment shall be submitted to EPD for agreement prior to commencement of assessment.

15.7.9            Land contamination assessment and remediation shall be completed prior to the development of the Project. If deemed necessary, the contaminated sites shall be remediated before commencement of any construction works which may disturb the ground. In all cases, contaminated soil remediation, treatment or disposal must be managed in an environmentally sound manner, including compliance with all relevant legislation and Government requirements.

15.7.10         Remediation options for the land contamination assessment are discussed in Section 8.5. The remediation method adopted will be based upon results of the site investigation, and views from the relevant authorities would be sought for the remediation technologies that are not included in the Practice Guide.

15.7.11         The establishment and implementation of the supplementary CAP, CAR and/or RAP will minimise potential adverse impacts to the environment arised from land contamination and site remediation activities. No adverse residual impacts are anticipated from the construction and operation of Project activities.

15.8                 Ecology Impact

15.8.1            The ecological impact assessment was conducted in accordance with the requirements set out under Annexes 8 and 16 of the TM-EIAO, Section 3.4.9 and Appendix H of the EIA Study Brief, EIAO Guidance Notes (6/2010, 7/2010 and 10/2010) and other relevant legislations and guidelines. The assessment area for ecological impact assessment includes the area within 500m from the boundary of the Project Site.

15.8.2            Based on the selected Development Option 2, the associated ecological impacts have been considered and assessed.  The proposed development will avoid areas of higher ecological values i.e. Sub-Areas 2 to 4 (medium or medium to high ecological values), only Sub-Area 1 with relatively lower ecological value (low to medium) will be developed. Direct impacts to most of the important habitats (e.g. swampy woodland with very rare Glyptostrobus pensilis) and species of conservation importance are not expected. Besides, the hydrological disruption due to the proposed development is not expected, potential impacts to the hydrology of the swampy woodland are thus not likely. With the implementation of the proposed management with the aims to protect the important habitats and species of conservation importance in Sub-Areas 2 to 4, the ecological conditions will be conserved and probably be enhanced.

15.8.3            As woodland and mixed woodland are identified within Sub-Area 1, in order to minimize the potential impacts due to habitat loss (i.e. 4.11ha of woodland and mixed woodland) and site formation, a number of mitigation measures will be implemented. Compensation woodland planting will be provided (~5.1 ha, larger than the loss of 4.11ha woodland and mixed woodland) and opportunities of in advance planting will be explored. Plant species of conservation importance recorded within Sub-Area 1 will be retained as far as possible or transplanted. As Sub-Area 2 and Sub-Area 3 will only provide recreational facilities and ancillary facilities, and no works is proposed in Sub-Area 4, no adverse ecological impacts are anticipated.

15.8.4            Sub-Areas 2 to 4 are intended to be zoned as “Other Specified Uses” annotated “Recreation cum Conservation” under Outline Zoning Plan. Hence, Sub-Areas 2 to 4 should be conserved and a management plan will be formulated with the aims to manage the human activities conducted in Sub-Areas 2 to 4 and conserve the ecologically sensitive habitats and species of conservation importance from disturbance. With the future management plan, the potential indirect impacts from disturbance (e.g. noise, traffic and human disturbance) to the important habitats in Sub-Areas 2 to 4 and the habitats in the vicinity as well as the species of conservation importance can be further reduced. A monitoring programme will be included in the management plan to evaluate the effectiveness of the management strategies.

15.8.5            With the implementation of mitigation measures, the residual ecological impact from the proposed development is considered acceptable.

15.9                 Fisheries Impact

15.9.1            A study based on existing information on pond culture fisheries resources and activities within the assessment area has been undertaken, following the criteria and guidelines for evaluating and assessing fisheries impact as stated in Annexes 9 and 17 of the TM-EIAO.

15.9.2            The proposed development will be conducted within the Project Site. No loss of active or inactive fish ponds are anticipated. With the implementation of mitigation measures recommended in Section 5 of this EIA Report for controlling water quality impact, the Project would not cause any unacceptable water quality impact to adjacent fish ponds or watercourses that provide water supply for fish ponds during construction and normal operation.

15.10              Landscape and Visual Impacts

15.10.1         The proposed public housing development will inevitably result in some landscape and certain visual impacts. The works will be conducted within Golf Course Landscape (LCA1).  Golf Club Building (LR8.1) and Carpark in Golf Course (LR8.2) are expected to receive the most impact due to the large percentage of area to be affected.  Natural Woodland in Golf Course (LR1.1), Secondary Woodland in Golf Course (LR1.2) and Grassland (LR2) will also be affected due to the large total area size.  It is not possible to fully mitigate all landscape impacts in relation to the loss of trees and other vegetation during construction and operation phase. However, the impacts have been reduced through minimization of construction and temporary works area with construction control, incorporation of aesthetic landscape and architectural design and providing more greening around the Development and associated infrastructure works.  Residual impacts to LRs and LCAs will provide slight to moderate landscape impact by Year 10 when the proposed mitigation measures are in full effect.

Visual Impact

Construction Phase

15.10.2           With the implementation of mitigation measures such as the control of night-time lighting glare, good site practice, erection of decorative screen hoarding, preservation of existing vegetation, part of the residual visual impacts of construction phase is expected to be alleviated and ranged from substantial adverse to insubstantial in construction phase. 

Operation Phase (Year 10)

15.10.3           With the implementation of mitigation measures, residual visual impact of operation phase (Year 10) is expected to be alleviated and ranged from substantial adverse to insubstantial. The proposed staggered built forms and sensitive treatment and design of external finish of the built elements, together with landscape treatment around and within the perimeter of the site, podium gardens, retention of mature trees and trees of high amenity value, can alleviate the visual impacts on certain VSRs and enhance the visual quality for residents of the proposed public housing development.  To further enhance of the visual quality, Sub-areas 2-4 of the PDA will receive landscape treatment and additional planting

15.10.4         In conclusion, the visual impacts can be alleviated to a certain extent with implementation of mitigation measures, and are considered acceptable.

15.11              Cultural Heritage

15.11.1         The main issue in the cultural heritage impact assessment is the grading of Fanling Golf Course, Hong Kong Golf Club, currently a New Item pending for grading by Antiquities Advisory Board (AAB).  The Old Course, constructed in 1911, is part of the New Item. It may be directly and adversely affected by the housing development in Sub-Area 1 and the minor development and change of use within Sub-Area 2 to 4.   Three Graded historic buildings, Grade 1 Fanling Lodge, Grade 2 Clubhouse of HKGC and Grade 3 Half-way House of HKGC, and six clan graves may be indirectly affected by the proposed development option. One clan grave (G-01) will require relocation.  Mitigation recommendations for built heritage include possible green screening for the two graded historic buildings depending on the final location, design and height of the development and further measures, such as condition survey, monitoring, implementing buffer zones and ensuring safe public access may be required during the construction phase for the clan graves.  The mitigation measures are to be determined in a detailed built heritage impact assessment during the detailed design stage. For all the graded, not-graded historic buildings and clan graves, the overall impact is ranging from Acceptable to Acceptable with mitigation.

15.1.2              Desk-based review indicates that existing impacts associated with the construction and maintenance of the golf course would have affected archaeological potential of large parts of Sub-Area 1.  Three small areas within a wooded area are identified as original landforms and are tentative proposed for archaeological field investigation.   Minor development within Sub-Areas 2 to 4 may equally affect pockets of original landform, but extent of development within both Sub-Area 1 and Sub-Area 2 to 4 is yet unknown.

15.1.3              In addition, some archaeological potential exist around the proposed drainage and minor road upgrade works to the east of Sub-Area 1 or as yet decided works associated with minor works in Sub-Areas 2 to 4, although the some of the proposed impacts will occur on and along existing roads and drainage channels. Depending on the details of the proposed associated and/or drainage and minor road upgrade works to be reviewed in detailed archaeological impact assessment at later stage (and prior to detailed design stage), an archaeological field survey (prior to construction phase) is required if areas outside the existing roads and drainage channels are affected, or archaeological watching brief (during construction phase) is required if works are within existing impact areas such as existing roads and drainage channels. Review should be undertaken for Sub-Area 1 and Sub-Areas 2 to 4 (associated) works prior to other investigations including ground investigation, investigation for land contamination and so on in order not to disturb the site.

15.11.2           A detailed archaeological impact assessment including archaeological field survey, including field scan, auger tests and test pit excavation will be required within Sub-Area 1 and select areas within Sub-Areas 2 to 4 if development is confirmed. The archaeological survey and archaeological impact assessment should be conducted prior to other investigations including ground investigation, investigation for land contamination and so on in order not to disturb the site and the archaeological field guide the development and record archaeological information, if any.

15.11.3            Further assessment pending to the grading of the New Item conducted by AAB and mitigation measures, where necessary, will be proposed to AMO for agreement.

15.12              Environmental Monitoring and Audit Requirements

15.12.1         It is recommended to implement an EM&A programme to monitor the environmental impacts on the neighbouring sensitive receivers regularly. An EM&A Manual is prepared to specify the monitoring requirements, timeframe and responsibilities for the implementation of the environmental mitigation measures identified in the EIA report. An Environmental Mitigation Implementation Scheme as stated in the EIA report and EM&A Manual has summarised all the measures, the implementation locations, timeframe, agency etc. and required to strictly follow.