Item 1 : Transport Department

Ref : KR 182/192-51

Dated 1 August 2000

I refer to your above quoted letter of 19.7.2000 enclosing the Environmental Impact Assessment (EIA) Report and the Environmental Monitoring and Audit (EM&A) Manual for the above project.  I have the following comments :

EIA Report

(i)                  In para. ES1.1 and para. 2.2, the radius of Link Road L should be 63m instead of 88m.

(ii)                I note that the Year 2018 traffic flow in some of the locations in Annex A of the report are not consistent with what I have approved before.  You are required to provide updated information in your assessment.

Noted.  The text has been revised accordingly.

Year 2018 traffic flow, approved by your office with letter ref. KR182/192-S1 dated 19^th July, was used for carried out the environmental assessment (refer to Annex G – Samples of Road Traffic Noise Modelling Input for details).  The updated information of traffic figures and numerical values has been incorporated into the EIA report.

(iii)               In para. 4.4.3, it indicated that only the traffic flow data for am peak-hour was adopted for assessing the traffic noise impact on the surrounding developments.  Would the pm peak-hour traffic flow be used in the assessment ?  Please clarify this.

Based on the traffic flow data generated specifically for this study, it was found that the dominant traffic noise sources including West Kowloon Expressway and Route 9 are located close to the selected NSRs (i.e. Mei Foo Sun Chuen, KMB CDA and Site 10) and majority of these road segments show the comparably higher traffic flow for the a.m. period than p.m. period.

(iv)              In para. 4.4.3, it mentioned that the Year 2018 was considered as the worst case year and the traffic flow data of that year had been used in this assessment to evaluate the road traffic noise impacts.  However, I consider that the traffic noise contributed by Link Road G & L just before the opening of Route 9 (Year 2006) is also critical.  You may wish to make a comparison between the two sets of results.

According to the traffic flow data generated specifically for this study, it was observed that the majority of the road segments such as West Kowloon Expressway, indicate the higher traffic flow during the period of Year 2018 when compared with the Year 2006 traffic flow.  Furthermore, a new network of Route 9, located close to the selected NSRs (i.e. Mei Foo Sun Chuen, KMB CDA and Site 10) would be open after the year of 2006 and would thus contribute further noise impacts compared to the year 2006.   Based on the above grounds, Year 2018 traffic flow data should be used for the assessment as the results show the worst case scenario.

EM&A Manual

I have no comment on the EM&A Manual from a traffic engineering viewpoint.

Noted.

Item 2 : Planning  Department

Ref : ( ) in PD/TKS S/ENV/6

Dated 3 August 2000

Reference is made to your letter of 19.7.2000 and the Environmental Impact Assessment (EIA) Report and the Environmental Monitoring and Audit Manual on the above subject.  I append below the following comments on the EIA report for your consideration please :

(a)        Following the completion of the West Kowloon Reclamation Comprehensive Traffic Analysis Review and Environmental Impact Assessment Study in June 1997, TDD commissioned a further land-uses review known as “Review of Land Use in the Northern Part of the West Kowloon Reclamation” to assess the suitability of housing development in the northern part of West Kowloon Reclamation.  The land-use review report was completed in April 1998 and thus should be taken into account in the planning review of this environmental impact assessment.

The report entitled “Review of Land Use in the Northern Part of the West Kowloon Reclamation” had been taken into account prior to the preparation of an environmental impact assessment.  Site 10 is the area which is most likely to be affected by the Link Roads G & L.

 (b)       As the construction of Link Roads G and L would environmentally affect the proposed development in Site 10 which is one of the sensitive receivers, comments from Housing Department on the EIA report should be sought.

Please note that comments from our landscaping team will be forwarded to you later.

Noted.  Copies of EIA report and EM&A Manual have been sent to Housing Department for comment.

Noted.

Item 3 : Environmental Protection Department

Ref : (25) in EP1/K20/WKR/89 III

Dated 10 August 2000

We refer to your above reference letter concerning the draft EIA Report and the EM&A Manual for the above project.  Please find attached our advisory comments on the submitted documents.  You may need to check with the visual / landscaping team of the Planning Department to confirm whether they have any comment on the above.

Noted.

Please feel free to inform us if you require our assistance in resolving any issues before the formal submission.  We would be happy to convene a Study Management Group meeting to assist if necessary.

Noted with thanks.

(A)              EIA Report

(a)                Air Issues

General

Please spell out the claim in the letter ref. T285/111(p)/12 dated 5.7.2000 in to the text of the EIA report.

Noted..

Table 3.4

The detailed calculations of the emission factor for the construction activities should be provided for our review.

Noted.  This has been incorporated into the text of the EIA Report.

S3.5.3

The Consultants should clarify if there is any other construction activities within 500m of the site boundary taking place in parallel with the project.  If yes, the cumulative dust impacts of these concurrent activities should also be taken into account for the assessment.

Construction of Route 9 – Tsing Yi to Cheung Sha Wan will take place in parallel with this project.  The cumulative dust impacts have been taken into account.

Table 3.5 – Note (1)

The Consultants please confirm whether the background TSP concentration has only been included in the predicted daily TSP levels but no also the hourly levels.

Confirmed that the background TSP concentration has been included in both the predicted daily and hourly TSP levels.

S.3.5.5 and S.3.6.4

The term of “adverse” should be added between “no” and “residual”.

Noted, the text shall be modified accordingly.

Fig. 3.2a and b

Contour lines covering the whole study area within 500m of the site boundary should be presented and the identified ASRs should also be highlighted in the maps.

Noted and contour lines have been included.

Annex B

The Consultants should explain why the traffic volume found in Annex B are inconsistent with those given in Annex A.

Noted.  Please refer to the response given in item 1(ii).

Annex C

The anemometer height used in the FDM model for the Cheung Sha Wan Station is incorrect.  The correct value should be 29.6m.  Also, NO₂ concentrations at the receivers were modelled at three wind directions (140, 150 and 240 degree).  However, RSP concentration were modelled with the worst hit angle.  The Consultants should adopt a consistent approach for CALINE4 model.

Noted.  This assumption has been modified and the data re-modelled.

Due to the limitations of Caline 4 model, predicted NO₂ concentration was modelled for all wind directions to more realistically represent the actual situation.  To be environmentally friendly, output files for the three worst wind directions have been printed out.  The output files for all wind directions have been put in electronic format as requested.

As summation of the modelled results from separate source files is a more conservative way and no exceedance of RSP level was predicted at any selected receivers, extra effort to be modelled at defined wind directions was unlikely to be required.

Others

All the input and output files in electronic format should be submitted to EPD for review.

Noted.

(b)                Noise Issues’

Assessment Points for NSRs

The facades at which assessment points 10S1 and 10S2 are assigned in this current EIA may not be noise sensitive facades as noted from the EIA of Route 16 (Alternative Alignment) – West Kowloon to Shatin dated 1999.  The Consultants should review the assessment points with reference to the proposed building design of Site 10 to ensure that they are at appropriate locations.  Moreover, supporting information such as proposed floor layout plans should be provided in the EIA.

Due to the variety of geometrical shape between Link Roads G & L and Route 16 (Alternative Alignment) i.e. different characteristics of traffic noise sources, and based on the proposal floor layout plans of Site 10, the criteria of selection of assessment points would be different from Route 16 and hence receivers of 10S1 and 10S2 are believed to be the representative receivers subjected to the adverse noise impacts from Link Roads G & L.  Furthermore, supplementary information including proposal floor layout plans has been incorporated into the EIA report for your review.

Accuracy of Operational Noise Prediction

From our estimation during spot check on the operational noise prediction, it seems that the 2018 predicted noise levels from “New Road” at KMB1, KMB3 and 10S6 shown in the draft EIA is on the high side.

Noted, please see below for clarification.

In view of the above, the Consultants are required to provide the following information for our further checking of the operational noise assessment results.

(i)                  Site plan in 1:1000 or 1:2000 scale showing :

-                      the proposed Link Road G, L and

-                       

-                      “Other Roads”.

-           the road surface levels in mPD levels at about 50m interval,

-                      the NSRs in the assessment (with assessment points clearly marked).

Noted.  The site plan with mark-up details has been attached separately for your checking.

(ii)        Roadplot with all roads, barriers (including all kerbside crash wall on viaducts such as Route 9 and West Kowloon Expressway) and road segment numbers marked and “New Road” extent marked.

Noted.  Roadplot with mark-up details has been incorporated into the EIA report.

(iii)       Calculation breakdown for Mid Level of MF4, Low Level of KMB1 and 3 in the format of the attached table.

(iv)       Cross-sectional views for the above mentioned NSRs at MF4, KMB1 and 3 showing the roads concerned, topographical screening and the NSRs.

Noted.  The required breakdown noise calculation has been attached separately for your checking.

Noted.  The required figure of cross-sectional views showing the concerned information has been attached separately for your checking.

Moreover, the 2018 predicted noise levels form “Other Road” at some NSRs such as MF4, KMB1 to 3 and 10S6 shown in this EIA is much (up to about 8 dB(A)) higher than the noise levels predicted in the EIA of Route 9 at the corresponding NSRs at the same locations.  Given the differences are so large, it is suspected that the Consultants may not have incorporated all direct noise mitigation measures recommended in the relevant EIAs (e.g. EIA for Route 9 – Tsing Yi to Cheung Sha wan, EIA for Route 16 (Alternative Alignment) – west Kowloon to Shatin, West Kowloon Expressway, etc.).  Therefore, the Consultants should list out all the direct noise mitigation measures in the relevant EIAs considered in this current noise modelling and show them in figures.

·         Direct noise mitigation measures of West Kowloon Expressway according to the drawing details provided by the relevant consultants are incorporated into our current noise modelling.  The details are presented in the following :

·         3m high roadside noise barrier located on the northern side of eastbound main carriageway of West Kowloon Expressway.

·         3m high roadside noise barrier located on the northern side of westbound main carriageway of West Kowloon Expressway.

·         Provision of Low Noise Surfacing on the eastbound and westbound main carriageway of West Kowloon Expressway.

·         Direct noise mitigation measures recommended by the relevant EIA and based on further drawing details provided by the Consultants (Hyder / Arup) are considered in our current noise modelling and listed out as follows :

·         3m high roadside noise barrier located along the western side of the northbound carriageway of Route 9.

·         5m high roadside noise barrier located along the eastern side of the northbound carriageway of Route 9.

·         5m high roadside noise barrier located along the eastern side of the southbound carriageway of Route 9.

·         Full enclosure located at northbound carriageway of Route 9 slip road.

·         Semi-enclosure / Full enclosure located at southbound carriageway of Route 9 slip road.

·         3m high roadside noise barrier located on the western side of the northbound carriageway of Route 9 slip road.

·         3m high roadside noise barrier located on the eastern side of the southbound carriageway of Route 9 slip road.

·         3m high roadside noise barrier located on the western side of the northbound carriageway of Route 9 near the Lai Wan Interchange.

·         3m high roadside noise barrier located on the eastern side of the southbound carriageway of Route 9 near the Lai Wan Interchange.

·         3m high roadside noise barrier located on the northern side of the eastbound carriageway of Route 9 slip road near the Lai Wan Interchange.

·         Provision of Low Noise Surfacing on the northbound main carriageway of Route 9 and its slip road (Ramp G).

·         Provision of Low Noise Surfacing on the southbound main carriagway and its slip road (Ram H).

Development KMB CDA Site

From traffic noise assessment result, it is noted that the screening effect by the KMB CDA Site is taken into account when assessing the traffic noise impact on Mei Foo Sun Chuen.  The Consultants should confirm whether there will be a scenario which developments in the KMB CDA Site has not been completed prior to construction and operation of Road G and L.  If affirmative, the traffic noise impact assessment at Mei Foo Sun Chuen should taken this scenario into account.

Year 2018 traffic flow data was used for the assessment of traffic noise at the selected receivers.  The dwellings in the vicinity of proposed development during the year 2018, would be therefore be modelled for the study.  Furthermore, based on the information from the Planners (Townland Consultants), the construction period is between year 2002 – 2004 (much earlier than year 2018).  We confirm that the screening effect by the KMB CDA site should be taken into account when assessing the traffic noise impact on Mei Foo Sun Chuen.

Accuracy of Construction Noise Prediction

From our estimation, it seems that the Consultants has under-estimated the construction noise levels (by a few dB(A)).  Therefore, we have reservation on the accuracy of construction predictions.  The Consultants are required to provide sample calculation for MF3 in Mitigation 3 scenario for our vetting.

Noted.  As cumulative construction noise impact assessment has been re-assessed.  The detailed calculation for MF3 in mitigation 1 scenario is shown in Annexes D and E of EIA report for your reference.

S.4.2.3

The following paragraph should be added to the end of the section :

“Despite any description or assessment made in the subsequent paragraphs, the Noise Control Authority will be guided by the relevant Technical Memorandum (Memorandum) in assessing an application, once filed, for a Construction Noise Permit.  He will consider all the factors affecting his decision taking contemporary situations / conditions into account.  Nothing in this Report shall bind the Authority in making his decision.  There is no guarantee that a Construction Noise Permit will be issued.  If a permit is to be issued, the Authority shall include any condition he thinks fit and such conditions are to be followed while the works covered by the permit are being carried out.  Failing which will lead to cancellation of the permit and prosecution action under the NCO.”

Noted.  The suggested paragraph has been incorporated into the EIA report.

S.4.2.4, Last paragraph of Page 4-3

As Exco directive is not referred in EIAO-TM or Study Brief, the Consultants should remove all wording about “Exco directive” in this report.

Noted.

S.4.2.6

The Consultants should provide justification on the assumption that the Site 10 and KMB CDA have not been occupied when Road G and L is under construction.

According to the information from the Architects and Planners (Wong & Tai Associates Ltd. and Townland Consultants Ltd.), the construction period for Site 10 and KMB CDA are year 2000 to 2004 and year 2002 to 2004 respectively.  As the construction period for Link Roads G&L is between year 2001 to 2003, Site 10 and KMB CDA will not be occupied when Road G and L is under construction and therefore are not considered to be SR’s.

S.4.3

The Consultants should spell out in the text of the report whether TDD (the project proponent) has agreed to the construction programme, equipment inventory and the recommended mitigation measures (the silenced equipment, limiting of plants and temporary noise barriers, etc.) used in the construction noise assessment.

The Consultants should address the cumulative construction noise impact from Route 9 and this project.

Noted.  TDD has agreed to the construction programme, equipment inventory and the recommended mitigation measures (the silenced equipment) limiting of plants and temporary noise barriers).

Noted.  Cumulative construction noise impact from Route 9 and Link Roads G & L has been reassessed and the details have incorporated into the EIA Report.

S.4.4.2

In order to substantiate whether the assessment points for planned NSRs proposed in this section can represent all planned NSRs, the Consultants should provide the OZPs for the area in the vicinity of the road project in this project.

Moreover, the Consultants should spell out in the text of the report if Plan D has been consulted on whether all approved re-zoning or TPO Section 16 application for planned NSR are included in the study.

Noted.  The OZPs for the area in the vicinity of the road project has attached separately for your checking.

Noted.  Plan D has been consulted on all approved re-zoning or TPO Section 16 application for planned NSR within the study area and such details have incorporated into the annex of EIA report.

S.4.4.3

It seems that the traffic data shown in Annex A of the report is much different from the traffic data in the EIA of Route 16 – West Kowloon to Shatin

(Alternative Alignment).  Some of the examples are listed as follows.  Transport Department may like to comment on this issue.

                        Road 16*          Current EIA

Road G                624                      904

Road L                960                    1666

(N.B. : Traffic data is shown in veh/hr)

*          EIA of Route 16 – West Kowloon to Shatin (Alternative Alignment), please contact Highways Department for further details.

In addition, the Consultants should amend the traffic data shown in Annex A so as include the % of heavy vehicles (defined in CRTN).

Noted.  It is understood that that the traffic data of the EIA of “Route 16 – West Kowloon to Shatin (Alternative Alignment)” (CE42/96) quoted in EPD’s letter were produced in 1998 and were developed from the old version of planning data as well as network assumptions.  Thus, the flows we outdated and superseded by the new data produced by “Agreement no. CE50/98 Design and Construction Assignment for Route 9 between Cheung Sha Wan and Sha Tin” in recent (May 2000).  Our (WK30) 2018 traffic flows have been compared with the 2020 traffic flows of the new Route 9 project (CE50/98) and the results are acceptable for TD.  (Please see attached MVA’s letter of 14^th July 2000 and TD’s letter of 19^th July 2000).

Noted.  Amended traffic data with the percentage of heavy vehicles indicated has been incorporated in the tables of Annex A of EIA report.

S.4.4.4, Page 4-14, Paragraph “Without any form …..”

The Consultants should clarify whether the “dwellings and classrooms to be affected:” are affected by other existing roads.

Yes.

S.6.2

-                      The 2^nd sentence should be revised as “The purpose of this monitoring is to verify the prediction of operation noise levels in the EIA study”.

-                      The project proponent shall be responsible for the monitoring.  The Consultants should amend the 3^rd sentence.

-          Typo : “Route 10” in the 2^nd sentence paragraph should be amended as “Roads G and L”.

-           The Consultants should also consider recommending the comparison of the noise prediction result and the noise monitoring result to verify the prediction.

Noted.  The text has been revised accordingly.

Noted.  The text has been revised accordingly.

Noted.  The text has been revised accordingly.

Noted.  The text has been revised accordingly.

The Consultants may like to revise this section with reference to the operational noise monitoring in other recently approved EIAs, e.g. Widening of Tolo Highway / Fanling Highway between Island House Interchange and Wo Hop Shek Interchange in the EIAO Register.

Noted .  The text has been revised accordingly.

Annex D

The Consultants should confirm whether the plant inventory shown in Annex D has included all the activities mentioned in Figure 2.1 of the report, e.g. site clearance, formation, site formation, drainage / utilities, landscape, etc.

Plant inventory shown in Annex D has covered all the activities mentioned in Figure 2.1 of the report.

S.4.5.21 and 7.2 (as well as Executive Summary)

The Consultants have recommended self-protective building design, etc., in the planned NSRs such as Site 10 and KMB CDA for mitigation of traffic noise.  If there is no residual impact from Roads G and L, the above said recommendation is irrelevant.  The relevant text should be deleted.

Noted.

Summary of Environmental Outcomes

Please provide a separate section as a Summary of Environmental Outcome in accordance with the Study Brief.  An example is attached for your convenient reference.

Noted.  Summary of Environmental outcome has been incorporated into the EIA report.

(B)              EM&A Manual

S.2, para 2.3(a)

The value is missing.

The value has been included.

Table 2.1

Only one air monitoring station is proposed at ASR9, what about other ASR like ASR 8, 10, 13 etc..

Typo “ASR 9” in Table 2.1 of para 2.5 has been revised as ASR10.  Apart from air monitoring station at ASR10, an additional station, ASR12 is chosen for air monitoring.

Table 3.1

Only one noise monitoring station is proposed at MF3, what about other NSR like ASR 1, 2, 4, 5 etc..

Apart from noise monitoring stations at MF3, an additional station, MF5 is chosen for noise monitoring.

Operational Noise Monitoring

The Consultants should amend the operational noise monitoring sections according to the above comment on S.6.2.

Noted.

Implementation Status Proforma and Compliant Log

Please include an Implementation Status Proforma and Compliant Log in the EM&A Manual.  Examples are attached for your convenient reference.

Noted. An Implementation Status Proforma and Complaint Log have been included in the EM&A Manual

(C)              Executive Summary

Please also provide the Executive Summary as standalone documents in both English and Chinese with figures after the draft EIA and EM&A Manual are tidied up.

Noted.

Comments

Responses

Item 4 : Environmental Protection Department

Ref : ( ) in EP2/K20/A/13II

Dated 11 October 2000

Thank you for the EIA Report you submitted on 7 September.  During our review process, a number of areas have been identified in the Report where clarification would be useful and I have set out these areas below.  These comments are provided informally in advance of our statutory reply under the EIAO.  We would be pleased to meet with you and your consultants to discuss these comments or alternatively, you may consider providing clarifications in the form of amendments to the Report before we meet.

General Comments

2.                   Recent road projects have raised questions from the public and legislators about the project justification and the impacts both with and without the projects.  There have been requests for additional mitigation measures to be included to address overall impacts, even those not related to the project.  The Report needs to address such issues in line with the requirements of the Technical Memorandum. In particular, it would be useful to more clearly delineate the impacts on sensitive receivers specifically attributable to Link Roads G & L being in place and also without them.  Specific suggestions are set out below.

Noted.

Comments

Responses

Specific Comments

Section 3.6.2, Section 4.4.3 and Annex A

3.         All of the traffic flow figures including traffic forecasts without Link Roads G and L in place should be included.  It is necessary (TM4.4.2.g) to indicate the potential impacts both with and without the project.

We agree with the statement that the potential impacts both with and without the project are required under the EIAO-TM however it is standard practise to predict the prevailing impacts and forecast the future impacts using noise models. The indication of the “with/without” scenarios has not previously required. The provision of model calculations and thus we have adopted the standard approach for this project. The traffic flow figures in the year 2001 of the existing network without Link Roads G and L in place are provided in Annex A.  Moreover, results of the traffic noise impact in the prevailing year without the project were predicted and given in Annex F. However, the traffic flow figures excluding Link Roads G & L in the year of 2018 were not specifically modelled but two additional sections (3.6.4 and 4.4.5) have been included to address the environmental implications of the project.

Section 3.6.3 and 3.6.6 and Table 3.7

4.         A quantitative assessment of the impacts on sensitive receivers with and without the project should be provided.  Table 3.7 should have an additional column to indicate the impacts without Link Roads G and L in place.  The text of the conclusions section should be amended accordingly to bring out the environmental benefits and disbenefits.

As discussed at our meeting on Friday, 27 October, and described above a quantitative assessment of the air quality impacts without Link Roads G & L in the year of 2018 has not been undertaken as the traffic flow figures for such a scenario are not available.  An additional section 3.6.4 has been included to bring out the environmental implications of the project and the section of conclusion (S3.6.7) was also revised.

Section 4.2.4 (Paragraph 2 and 3 of Page 4-4)

5.                   The three criteria for the Indirect Technical Remedies eligibility test noted in the Study Brief (Section 3.3.2.2(vi)(c)) should be listed instead of referring to the EIAO-TM which does not stipulate the relevant criteria.

Noted.  The text has been revised accordingly.

Comments

Responses

Section 4.3 (The last paragraph)

6.         The text should state whether the Highways Department has confirmed the construction programmes / periods for Route 9 (Tsing Yi to Cheung Sha Wan) and Route 9 (West Kowloon to Shatin).

Noted.  As discussed in Section 4.3, the construction programmes of Route 9 – Tsing Yi to Cheung Sha Wan need for the assessment was extracted from the approved EIA report under Register No. EIA-025/1999.  The corresponding text has been revised accordingly.

Section 4.4.3 and Figure 4.3

7.         The noise modelling assumptions used for traffic noise impacts from Link Roads G and L should be clarified.  For example, did the assumptions include a parapet to act as a noise barrier?

Noted.  The assumptions have been set out in Section 4.4.3 and included the 0.8m high parapets which were modelled on the viaducts of Route 9, West Kowloon Highway and Link Roads G & L.

8.         It could be useful to consider the overall effect of notional noise barriers on Link Roads G and L.  Even though the TM requirements may be met without mitigation, in our experience the public expects maximum practicable measures to be implemented on new roads.  The Report should clearly indicate whether such barriers would have any effect in lowering overall noise levels at the effects NSRs.

Noted.  The model results have indicated that the contribution from the Link Roads G & L will be less than 1 dB(A).  The use of noise barriers would not have any discernible effect at the NSR’s and therefore is not recommended.  In addition to which, interpretation of the model results confirms that the requirements of the EIAO-TM can be met.

9.         The noise mitigation measures or Route 9 and West Kowloon Highway considered in the noise modelling should be clearly shown.  The noise mitigation measures on the West Kowloon Highway have not been shown in the figures and the mitigation measures on Route 9 shown in Figure 4.3a and b are not clearly identifiable.

Agreed.  The figures have been amended to clearly indicate the noise mitigation measures on the West Kowloon Highway (Figure 4.3c) and Route 9 (Figures 4.3a and b).

Comments

Responses

Section 4.4.4

10.        As noted above, a quantitative assessment of impacts on sensitive receivers both with and without the project should be provided.  The assessment needs to clearly show the situation if the project is not built.  The contribution from the project on individual receivers needs to be clearly delineated.

The assessments have been carried out to determine the effects of the Link Roads G & L.  Results of the quantitative assessment of traffic noise impact on sensitive receivers including the relative contribution from Link Roads G & L were described in Section 4.4.4. The contribution from Link Roads G & L has been predicted to be < 1dB(A) which is in compliance with the EIAO-TM. An additional Section 4.4.5 has been included to address the impacts on the NSR’s as a result of the provision of Link Roads G & L. The noise contribution from Link Roads G & L is also anticipated to be insignificant.

Section 4.5.2, Section 7.2 and the last paragraph of Section ES2 of the Executive Summary

11.               11.        The Report states that “the traffic noise levels from Link Roads G & L … will result in exceedances”, and to a layman this statement implies we should be  insisting on maximum practicable mitigation.  Since no specific mitigation is required as the contribution is less than 0.9 dB(A), in order to avoid misunderstanding this criteria needs to be more clearly explained.  The `impact’ statement should be revised along the following lines :

“the predicted traffic noise levels including the contribution from Link Roads G & L … will result in exceedances”

Agreed.  The text has been revised accordingly.

12.        The Report should stress that the EIAO-TM criteria for traffic noise can be complied with.  Unless an assessment of the effect of any additional noise mitigation measures is included, the difficulty in reducing the overall noise level is not apparent and consideration of engineering constraints is irrelevant.

Agreed.  The text has been revised accordingly.

Comments

Responses

Section 6.2.4, Table 6.3 Section 7 – Operational Phase EM&A

13.        The following floor levels for operational noise monitoring points should be considered :

            MF3 – Top level

            KMB1 – Low level

            10S1 – Mid level

Noted.  The text has been revised accordingly.

Annex K (Environmental Outcome Profile)

14.        The EOP needs to be rewritten to more clearly reflect the environmental impacts and benefits, as follows :

Population Protected : There is a substantial population protected by implementing mitigation measures during construction and this should be included under this heading.

Problem Avoided : This section needs to concentrate on environmental problems.  Traffic issues are part of the justification for undertaking the project.

Environmental Friendly Design : The first two paragraphs are confusing and should be rephrased for clarity.

Noted.  The text has been revised accordingly.

Noted.  The text has been revised accordingly.

Noted.  The text has been revised accordingly.

15.        Please don’t hesitate to contact me if you have any questions.  We would be happy to meet if necessary to discuss these issues once your consultant has proposed possible amendments.

Noted with thanks.

Comments

Responses

Item 5 : Environmental Protection Department

Ref : Through e-mail dated 27 October 2000

(A) Response-to-Comment

“(3) Section 3.6.2, Section 4.4.3 and Annex A” and “(10) Section 4.4.4” both under “Specific Comments”:

From the consultant’s response, the consultant intends to compare the “with/without” scenarios by comparing the followings –

(a)  The 2018 total traffic noise with the project (Roads G and L); and

(b)  The 2001 total traffic noise without the project (i.e., the prevailing traffic noise.

In order to compare purely the difference between “with/without” scenarios, the consultant should refer the “without” scenario to the situation without Roads G and L in 2018. Moreover, the consultant needs to assess the increase in traffic flow on other roads without Roads G and L in 2018 and subsequently evaluate whether there are increase in noise level in the NSR along those affected roads.

Regarding the revised contents in the EIA in this submission, please refer to the above comment in Paragraph 2 relevant to the comparison of “with/without” scenarios.

As the traffic forecasts without Link Roads G & L are not available, please refer to our response to comment no.3 previously made by EPD dated 11 October 2000. The appraisal of the “with/without” scenario has been made on the basis of the relative contribution of noise from Link Roads G & L. This has been predicted to be < 1dB(A) which is in compliance with the EIAO-TM. It has been surmised that if Link Roads G & L were not constructed then the forecast traffic would be mainly contributed over the other roads (such as  Kowloon West Highway, Route 9 and Route 16). This would generate major traffic impacts and is predicted to cause significant increase congestion and vehicle emissions.

Comments

Responses

(B) Revised Pages/Contents

Sections 4.5.2 and 7.2

For Paragraph 2 of Section 4.5.2, the result of the “with/without” comparison should be amended accordingly.

For both sections, the consultant has referred to HKPSG in the revised text. EIAO-TM should be referred to.

Figure 4.3a and 4.3b

As commented in our previous memo, the mitigation measures on Route 9 and 16 are not clearly shown and the quality of the drawings should be improved. However, the drawings is still of an unacceptable quality with mitigation measures not clearly shown.

Paragraph 2 of Section 4.5.2 has been deleted and an additional Section 3.6.4 has been included to address the environmental benefit/disbenefit of the project.

Noted.  The text has been revised.

Noted. Figures 4.3a and 4.3b have been revised.

Environmental Outcome Profile

It is noted that the following contents on this page does not tally with the information in the noise impact assessment chapter:

In the 2nd paragraph of “Population Protected”, the “existing roads such as Route9, Route 16…” in the 3rd line should be revised to “other roads such as Route 9, Route 16…” since these roads are planned roads.

The “0.9 dB(A)” in the last line should read as “1.0 dB(A)” according to the noise assessment result.

Noted.  The text has been revised accordingly.

(C) Air Quality

I have checked the model input and output files. The files with the Link Roads G&L are the same as the files in previous submission.

Noted.

Comments

Responses

In the calculations without the G&L, the Consultant simply removed the G&L road links from the model without adjusting the traffic figures.

Provided that the traffic figures are acceptable to TD, the air modelling approach and results are acceptable for our assessment.