A Project Profile for permission to apply directly for an Environmental Permit (EP) for the “Penfold Park Enhancement Project” (ref: PP-605/2020) was submitted under the Environmental Impact Assessment Ordinance (EIAO) on 29 June 2020. Permission was granted by the Director of Environmental Protection on 4 August 2020 (ref: DIR-275/2020), with conditions laid out in the EP (ref: EP-577/2020).

The Hong Kong Jockey Club (HKJC) has commissioned Mott MacDonald Hong Kong Limited (MMHK) as the Independent Environmental Checker (IEC) to audit the implementation of all measures recommended in the Project Profile and to oversee the environmental monitoring and auditing (EM&A) requirements of the Project. An Ecologist is also engaged for preparing relevant EP submissions and to carry out ecological monitoring before and during construction phase.

1.2 Purpose and Objectives of this Report

As identified in the Project Profile, Short-nosed Fruit Bat was noted roosting in Chinese Fan-palm located within the Project boundary. The Project Profile has suggested to conduct a detailed active search for bat roost before the commencement of construction to ensure no active bat roost will be directly affected by the construction. Accordingly, EP Condition 2.4 requires a Detailed Bat Roost Survey Report to be deposited with EPD no later than one month before the commencement of construction of the Project.

According to EP Condition 2.4, the objectives of this Detailed Bat Roost Survey Report are as follows:

· To report the abundance of bat species including Short-nosed Fruit Bat; and

· To report the findings of bat roost activities within the Project Boundary, particularly Short-nosed Fruit Bat utilising Chinese Fan-palms, and indicate the locations of active bat roost within the works area.

This Detailed Bat Roost Survey Report is prepared in accordance with EP Condition 2.4 for the Project.

2 Baseline Information and EM&A Requirements

2.1 Findings of Roost of Short-nosed Fruit Bat during Project Profile Stage

As mentioned in the Project Profile, Short-nosed Fruit Bat (Cynopterus sphinx), a bat species common in Hong Kong urban area, was observed roosting under fronds of Chines Fan-palms in the Park, which is a typical roosting habitat of the species in urban area.

The species is considered very widely distributed in urban and countryside areas throughout Hong Kong (AFCD, 2022). The species is protected under Wild Animals Protection Ordinance (Cap. 170), and is rated as Near Threatened in the Red List of China Vertebrates.

During the Project Profile stage, Chinese Fan-palms were inspected for presence of roosting Short-nosed Fruit Bat during daytime survey, and 10 individuals were recorded in the Park.

2.2 Impact Assessment for Potential Impact on Short-nosed Fruit Bat in the Project Profile

Impact to Short-nosed Fruit Bat was anticipated to be minor and acceptable, owing to the artificial nature of the Penfold Park and the species being well adapted to certain disturbance from visitors, and given the implementation of environmental protection measures suggested in the Project Profile.

To minimize the potential disturbance impacts on bat species, especially the Short-nosed Fruit Bat, Chinese Fan-palm within the Park will be preserved as far as practicable.

2.3 Environmental Monitoring and Audit Requirements

A detailed active search for bat roost shall be conducted before the commencement of construction to ensure no active bat roost will be directly affected by the construction.

3 Bat Roost Survey

3.1 Inspection Period

Bat roost surveys were undertaken on 5^th September 2022 and 14^th November 2022.

3.2 Methodology

Walkthrough surveys were conducted to examine the habitat and vegetation that are potential locations for bat roosts.

With reference to the methodology by Chan and Shek (2006) on survey for the Short-nosed Fruit Bat, the main hosting plant for the roosts of Short-nosed Fruit Bat is Chinese Fan-palm. The species is known to roost under modified fronds, and the roosts were characterized by collapsing fronds with circular bite marks along major veins. Thus, vegetation including Chinese Fan-palms were the focus for the bat roost survey.

A pair of 8x42 binoculars were used to aid the inspection of habitat and vegetation.

3.3 Inspection Findings

One bat roost with 2 Short-nosed Fruit Bats was found during the survey on 14^th November 2022 on a Chinese Fan-palm (Tree no. T0716), while none was observed on 5^th September 2022. Bite mark on fronds was not observed on both days, except on the Chinese Fan-palm with bats roosting on 14^th November 2022. It should be noted that the group size of Short-nosed Fruit Bat is highly variable for each roost, and daily movements of Short-nosed Fruit Bat individuals among roosts are common.

The Penfold Park was walked thoroughly to identify location of potential bat roost locations including fronds of Chinese Fan-palms. The vegetation was checked carefully by observing the underside of the trees with the aid of binoculars, and attention was paid to collapsed fronds of Chinese Fan-palms with bite marks, which may indicate presence of bat roosts.

During the survey on 5^th September 2022, some clusters of Chinese Fan-palm in the Park were observed to be over-pruned. As these trees might have been disturbed by maintenance works in the Park, they are less likely to serve as potential roosting location for the bats. In addition, as described in the Hong Kong Biodiversity Newsletter Issue No.11 (Chan and Shek, 2006), where a study was conducted to survey the Short-nosed Fruit Bat living under the modified fronds of Chinese Fan-palm in urban areas of Hong Kong, bite marks were observed in trees of 3m to 16m high, while colonies were found in trees of 3.5m to 16m high. Therefore, potential bat roost location should include clusters of Chinese Fan-palm of height 3m to 16m, that are not over-pruned, and away from human disturbance in the Park.

Representative photographs of bat roost identified and the vegetation inspected are shown in Appendix A. Location of bat roost and potential roosting location identified, and clusters of Chinese Fan-palms planned to be retained and felled, are shown in Figure 1.

3.4 Recommendations

The Chinese Fan-palm (Tree no. T0716) with bat roost observed is not planned to be felled according to the Tree Protection and Removal Plan dated 27 September 2022. However, since Chinese Fan-palms are recorded in the Park, the Short-nosed Fruit Bats may change their roosting location to the other Chinese Fan-palms. Therefore, it is recommended that Chinese Fan-palms should be inspected for bat roosts prior to any works that may cause potential impacts on the bats.

Additional ecological mitigation measures are also recommended to be implemented during construction phase to minimize direct impact on bat roosts, such as fencing off the area around any active bat roosts, avoid pruning Chinese Fan-palm during construction phase and use of noise barriers for noisy works in close vicinity to bat roosts. Further details are described in the Implementation Plan for Ecological Mitigation Measures, under Condition 2.5 of the EP. Measures for avoiding over-pruning and other disturbances to bats during operation phase will be covered separately in the Comprehensive Plan Management Plan under Condition 2.6 of the EP.

4 Conclusion

The Detailed Bat Roost Survey Report is prepared in accordance with EP Condition 2.4 for the Project. Bat roost survey was conducted on 5^th September 2022 and 14^th November 2022, focusing on potential locations of bat roost, including Chinese Fan-palms within the Penfold Park. One bat roost with 2 Short-nosed Fruit Bats was recorded on 14^th November 2022, while no bat roost was observed during the survey on 5^th September 2022. Representative photographs of bat roost identified, and vegetation inspected are shown in Appendix A. Location of bat roost identified is shown in Figure 1.

Since Short-nosed Fruit Bats may change their roosting location to the other Chinese Fan-palms, it is recommended that Chinese Fan-palms should be inspected for bat roosts prior to any works that may cause potential impacts on the bats. Ecological mitigation measures to be implemented during construction phase to minimize direct impact on bat roosts are described in the Implementation Plan for Ecological Mitigation Measures, under Condition 2.5 of the EP. Measures for avoiding over-pruning and other disturbances to bats during operation phase will be covered separately in the Comprehensive Plan Management Plan under Condition 2.6 of the EP.

5 Reference

1. Agriculture, Fisheries and Conservation Department. (2022). Hong Kong Biodiversity Information Hub. Retrieved from https://bih.gov.hk/en/species-database/species-information/index.html?id=4432

2. Chan, C.S.M. and Shek, C.T. (2006). Survey on the Short-nosed Fruit Bat (Cynopterus sphinx) in the urban areas of Hong Kong. Hong Kong Biodiversity, Issue No. 11: 8. Agriculture, Fisheries and Conservation Department, Hong Kong.

Appendix A

Representative Photos of Bat Roost Identified and Vegetation Inspected