Subject: Our comments on San Tin EIA Report [Print This Page] Author: HKBWS Suet Mei Time: 5/03/2024 18:40 Subject: Our comments on San Tin EIA Report
On 2 Feb 2024, just before the public holidays for the Chinese New Year, the government released the Environmental Impact Assessment (EIA) report for the San Tin/Lok Ma Chau Development Node (i.e. San Tin Technopole) for public inspection. The 30-day statutory consultation period ended on 2 March 2024. A significant number of mistakes and inadequacies in the San Tin EIA report have been uncovered before the end of the consultation period. Below are only some of the problems mostly related to the ecological impact on birds, which is probably just the tip of the iceberg.
1. No avoidance of habitat loss in pond of high ecological value
2. Refusal to re-apply for EIA Study Brief violate procedural justice
3. Misidentification of Designated Project (DP)
4. Project Area and Assessment Area should be extended
5. Underestimation of habitat ecological value due to the deficiency of 12-month baseline surveys and the incomplete review of existing available avifauna
datasets
6. Uncertain qualification for conducting the avifauna baseline survey and inadequate gatekeeping of EIA report before public inspection
7. Underestimation of ecological value as “piecemeal approach” and inappropriate assessment was adopted in the evaluation of pond habitat
8. Absence of firefly survey and comprehensive monitoring of Eurasian Otter
9. Significant environmental changes to the egretries and their surroundings
10. Direct loss in foraging and feeding ground for the egretries was neglected and the corresponding impacts were underestimated
11. Disruption of the flight corridor for breeding egrets and herons
12. Inadequate protection of the egretry using the Open Space zoning
13. Failed to identify and assess the impacts on the day roost of Black-crowned Night Herons in San Tin Pumping Station
14. Direct impacts on the loss in foraging ground for ardeids’ night roosts were ignored
15. Missed more than half of the breeding bird species in fishpond wetlands
16. Threats to the integrity of Deep Bay wetland ecosystem caused by previous and ongoing development projects
17. Further significant fragmentation of Deep Bay wetland ecosystem by the current project
18. Absence of light impact assessment
19. Inadequate Visual Impact Assessment
20. Only four species selected for the functional value calculation and the compensation requirement is unacceptable
21. Inappropriate assumption of the Exclusion Zone (EZ) and Reduced Density Zone (RDZ)
22. Over-estimation of the carrying capacity of the compensation wetlands
23. Unjustified 45% increase in functional value
24. Absence of habitat management plan of the Sam Po Shue Wetland Conservation Park (SPSWCP)
25. Inappropriate implementation timeline of SPSWCP
26. The proposed 35m eco-interface lacks buffering function
27. Bird collision risk may not be avoided or mitigated
28. Wetland Enhancement Measures outside the assessment area of the project
29. Cumulative ecological impacts and undesirable precedent set in Deep Bay area
