• Submissions to be sent in writing to Director of Environmental Protection and to Chair of the Advisory Committee on the Environment before 11th July addresses below.
• Adapt following guidelines. Up to you which points you wish to use. Do not use exact wording. Personalise your submission so it will count. Copy it Hong Kong Birdwatching Society.
• Refer to EIA Report on http://www.info.gov.hk/epd/eia.

Write to :

The writer objects to the proposed Spur Line from Sheung Shui to Lok Ma Chau because:

• Long Valley has high ecological value - EIA Report para 4.4.14, tables 4.10, 4.12-4.16
• Long Valley supports many Species of Conservation Importance - tables 4.2,4.3, 4.4
• Long Valley is Hong Kong's last area of freshwater agricultural habitat - para 2.2.6
• Spur Line would have significant adverse impact on ecology of Long Valley in Construction and Operational Phases - admitted in EIA Report
  • Line would go through ecologically sensitive freshwater marsh
  • Line would fragment Long Valley's wetland agricultural habitat
  • Line would disturb and destroy habitat for Species of Conservation Importance
• Long Valley has high landscape quality and sensitivity to change - paras 5.5.17,5.7.4
• Spur Line Viaduct would have high impact on the landscape - admitted - table 2.1
• EIA Study failed to consider avoidance of Long Valley
• EIA Report fails to justify need for Spur Line
  • Relies only on figures on 2 festival days to say overcrowding at Lo Wu
  • When West Rail already proposed
• EIA Study failed to do cumulative assessment
  • No assessment of cumulative impact of Fanling By-pass and Spur Line
  • No assessment of cumulative impact of West Rail Phase II and Spur Line
  • No consideration whether further adverse impact should be permitted following River Retraining Works in Long Valley
• A full Strategic EIA of all projects should be done before any permit is considered
• Strategic EIA should assess impact of planned Strategic Growth Area in Kwu Tung
• WWF and HKBWS have applied to Town Planning Board for zoning of whole of Long Valley as Conservation Area
  • Unique conservation value - significant ecological and landscape quality
  • Existing natural features and rural use should be retained and protected
  • EIA should now await outcome of zoning application
• EIA Report not consider compromise "Transport Corridor" proposed by HKBWS
  • North of Beas River route
  • North of retrained river channel
  • South of Fanling By-pass
  • Including West Rail
• Leaves south core and area north of "Corridor" intact
  • EIA Report proposes most environmentally damaging route, the Central Alignment
  • Freshwater marsh impacted by Central Alignment - EIA Report APP1
  • Central Alignment higher disturbance and Beas River route lower disturbance impact for Birds of Conservation importance - APP2, 7, 8
  • Beas River route would cause less fragmentation - para 2.9.5.1.3 - is preferable once rail is operational - table 2.3 - is preferred option ecologically - table 2.4
• Mitigation and Compensation proposed is not secured
  • No management planned for either Long Valley or Lok Ma Chau fishpond compensation areas
  • No entity in existence to manage areas - only a wetland management organisation. Who is this to be and have they agreed?
  • No provision for financing of management of areas, no sum of money, fund or Trust provided for
  • Detailed measures for physical management and maintenance of the landscape required
  • No guarantee of long term sustainability of mitigation and compensation measures - same as no compensation at all
• Mitigation and Compensation measures proposed are inadequate
  • Central Alignment and Beas River not equal ecologically as Report claims - para 2.9.5.1.3 - mitigation cannot be same as avoidance
  • Compensation Reserve would be under the viaduct - species of Conservation Importance sensitive to noise and disturbance above and would avoid
  • Measures not replace "like with like" - compensatory wetland underneath viaduct and near Beas River Channel not equivalent to existing habitat
  • Report accepts there is "scope for additional habitat provisionˇ¨ for 10 species of Conservation Importance - table 4.4
  • Applicant for permit should be asked: is Beas River compensation area now proposed additional to that already required under the River Channelisation project?
• Independent Environmental Consultants should be asked:
  • Is temporary wetland at side of site during Construction Phase effective to ensure species of Conservation Importance are not disturbed?
  • What would the environmental impact be of a more realistic wider footprint during the Construction phase?
  • Would wetland under viaduct be effective compensation to conserve species of Conservation Importance?
  • Would Beas River wetland bordered by Fanling Bypass be effective compensation to conserve species of Conservation Importance?

Copyright 1999, Hong Kong Bird Watching Society.
For comments and questions, please e-mail to hkbws@hkbws.org.hk.