3.2 Environmental
Legislation, Standards and Guidelines
3.4 Identification of
Air Sensitive Receivers
3.5 Construction
Phase Impact Assessment
3.6 Operational Phase
Impact Assessment
3.8 Environmental
Monitoring and Audit
TABLES
Table
3.1 Hong
Kong Air Quality Objectives
Table
3.2 Kwun
Tong Air Quality Monitoring Station Results (2015-2019)
Table
3.3 CO
Concentrations at EPD Mong Kok AQMS (2015 to 2019)
Table
3.4 Background
Concentrations from PATH Year 2020
Table
3.5 Representative
Air Sensitive Receivers (ASRs)
Table
3.6 Total
Quantity of Pollutant per Helicopter Flight
Table
3.7 Stability
Conversion Factor
Table
3.8 Kai
Tak Cruise Terminal Emissions Data
Table
3.9 Cumulative
Assessment Result during Operational Phase
FIGURES
Figure 3.1 Location
of Air Sensitive Receivers
Figure 3.2 Schematic
Helicopter Flight Path
Figure 3.3 Location of Cumulative Pollution
Source
Figure 3.4 Location
of Pollution Sources within 4km
APPENDICES
Appendix
3A Correspondence with GFS
Appendix 3B Calculation of Helicopter Emission
Appendix 3C NOT USED
Appendix 3D Locations of Environmental Paver
Appendix 3E Correspondence with Training Authority Clothing Industrial Kowloon Bay
Training Centre
Appendix
3F Correspondence with Hospital Authority
Appendix
3G Correspondence with CEDD
Appendix
3H Correspondence with FEHD and Towngas
Appendix
3I Correspondence with T2 Engineer
Representative
Appendix 3J Emission Factors of Marine Emission Sources
within 500m Assessment Area
Appendix
3K Cruise Terminal Schedule
Appendix 3L Emission Factors of Cruise Terminal
Appendix
3M Correspondence with Cruise Terminal
Appendix
3N Detailed Assumptions of AERMET
Appendix 3O AERMOD
input parameters
Appendix 3P Detailed Breakdown of Air Quality
Impact Assessment
3.1.1.1 The New Acute Hospital (NAH) in the Kai Tak Development Area will be a
new major acute general hospital located in central Kowloon region and provide
24-hour Accident and Emergency, in-patient, out-patient, ambulatory and
rehabilitation services, in addition to being a designated trauma centre. As
part of the acute hospital with trauma facilities, a helipad (the Project) will
be built at the rooftop of the Acute Block of the NAH, where the Accident &
Emergency Department and trauma centre will be located.
3.1.1.2 This section presents an air quality impact assessment of the Project,
identifying the air quality issues, assessing the potential for construction
and operational phase impacts and recommending mitigation measures where
necessary.
3.2.1.1 The air quality impact assessment has made reference to the criteria
from the Hong Kong Planning Standards and Guidelines (HKPSG), the Air Pollution
Control Ordinance (APCO) (Cap 311), and Annex 4 of the Technical Memorandum on
Environmental Impact Assessment Process (TM-EIAO).
3.2.2.1
Reference to the EIAO
and the associated TM-EIAO has been made for the assessment of air quality
impacts. Annexes 4 and 12 of the TM-EIAO
set out the criteria and guidelines for evaluating air quality impacts.
3.2.3.1
The APCO provides a
regulatory framework for controlling air pollutants from a variety of
stationary and mobile sources and encompasses a number of Air Quality
Objectives (AQOs). Moreover, the Government’s overall policy objectives for air
pollution are laid down in Chapter 9 of the HKPSG as follows:
·
Limit the contamination of the air in Hong Kong,
through land use planning and through the enforcement of the APCO, to safeguard
the health and well-being of the community; and
· Ensure that the AQOs for 7 common air pollutants are met as soon as possible.
3.2.3.2 The prevailing Air Quality Objectives (AQOs) represent the current
policy of the Government as regards the acceptable level of air pollutants
having taken into account a number of factors including public health.
3.2.3.3
The prevailing AQOs are
benchmarked against a combination of interim and ultimate air quality targets
in the World Health Organisation Air Quality Guidelines (WHO Guidelines) which
are promulgated for protection of public health.
3.2.3.4
The AQOs stipulate
concentrations for a range of pollutants namely sulphur dioxide (SO2),
respirable suspended particulates (RSP), fine suspended particulates (FSP),
nitrogen dioxide (NO2), carbon monoxide (CO), Ozone (O3)
and lead (Pb). The AQOs are shown
in Table 3.1.
Table 3.1 Hong Kong Air Quality Objectives
|
Pollutant |
Concentration(i) mg/m3 Averaging Time |
||||
|
10 Minutes |
1 Hour |
8 Hours |
24 Hours |
1 Year |
|
|
Sulphur Dioxide (SO2) |
500 (3) |
– |
– |
125 (3) |
– |
|
Respirable Suspended Particulates (RSP) |
– |
– |
– |
100 (9) |
50 (0) |
|
Fine Suspended Particulates (FSP) |
– |
– |
– |
75 (9) |
35 (0) |
|
Nitrogen Dioxide (NO2) |
– |
200 (18) |
– |
– |
40 (0) |
|
Carbon Monoxide (CO) |
– |
30,000 (0) |
10,000 (0) |
– |
– |
|
Ozone (O3) |
– |
– |
160 (9) |
– |
– |
|
Lead (Pb) |
– |
– |
– |
– |
0.5 (0) |
i.
Measured at 298K (25°C) and 101.325 kPa (one atmosphere)
ii.
Numbers in brackets “( )” indicates the number of
exceedances allowed.
3.2.3.5
The TM-EIAO stipulates
that the hourly total suspended particulates (TSP) level should not exceed 500 mg/m3 (measured at 25°C and one atmosphere) and this objective is
relevant to the construction dust impact assessment. Standard mitigation measures for
construction sites are specified in the Air Pollution Control (Construction
Dust) Regulation. Notifiable and
regulatory works are, also, under the control of the Air Pollution Control
(Construction Dust) Regulation, to which the Environmental Protection
Department should be informed.
3.2.4.1
The Air Pollution
Control (Construction Dust) Regulation specifies processes that require special
dust control. The Contractors are
required to inform EPD and adopt proper dust suppression measures while
carrying out “Notifiable Works” (which requires prior notification by the
regulation) and “Regulatory Works” to meet the requirements as defined under
the regulation.
3.2.5.1
The Air Pollution Control (Non-road Mobile
Machinery) (Emission) Regulation came into effect on 1 June 2015. Under the Regulation, non-road mobile
machinery (NRMMs), except those exempted, are required to comply with the
prescribed emission standards. From
1 September 2015, all regulated machines sold or leased for use in Hong Kong
must be approved or exempted with a proper label in a prescribed format issued
by EPD. Starting from 1 December
2015, only approved or exempted NRMMs with a proper label are allowed to be
used in specified activities and locations including construction sites. The Contractor would be required to
ensure the adopted machines or non-road vehicle under this Project could meet
the prescribed emission standards and requirements.
3.3.1.1 As shown in Figure 1.1, the proposed
helipad will be located on the rooftop of the proposed Acute Block of the NAH.
3.3.1.2 The existing air
sensitive receivers (ASRs) in the Assessment Area comprise mainly commercial
buildings, such as the Pacific Trade Centre and Octa Tower etc., planned
residential buildings and the Hong Kong Children’s Hospital. The Kwun Tong Bypass and Kai Fuk Road
are located in the vicinity of the proposed NAH and their vehicular emissions form
the major contributions to background air quality in this location.
3.3.2.1 The nearest
Environmental Protection Department (EPD) Air Quality Monitoring Station (AQMS)
to the Project site is the Kwun Tong AQMS located at Kwun Tong Police Station, which
is approximately 2km north-east of the Project Site. The latest 5 years of air quality data, that
is, 2015 to 2019, at the Kwun Tong AQMS are summarised in Table 3.2, depicting the trend in air quality.
Table 3.2 Kwun Tong Air Quality
Monitoring Station Results (2015-2019)
|
Pollutant |
Averaging Period |
Concentration (µg/m3) |
||||||
|
2015 |
2016 |
2017 |
2018 |
2019 |
5 Year Average |
Corres- ponding AQO |
||
|
SO2 |
10-min
(4th Highest) |
79 |
53 |
53 |
51 |
41 |
55 |
500 |
|
24-hr
(4th Highest) |
22 |
17 |
19 |
12 |
11 |
16 |
125 |
|
|
PM10 |
24-hr
(10th Highest) |
99 |
89 |
84 |
78 |
73 |
85 |
100 |
|
Annual |
44 |
37 |
39 |
38 |
38 |
39 |
50 |
|
|
PM2.5 |
24-hr
(10th Highest) |
65 |
50 |
53 |
45 |
44 |
51 |
75 |
|
Annual |
27 |
23 |
23 |
22 |
21 |
23 |
35 |
|
|
NO2 |
1-hr (19th
Highest) |
271 |
200 |
199 |
178 |
184 |
206 |
200 |
|
Annual |
55 |
54 |
44 |
43 |
45 |
48 |
40 |
|
|
O3 |
8-hr
(10th Highest) |
130 |
116 |
135 |
130 |
150 |
132 |
160 |
Note: Shaded
cell denotes exceedance of relevant AQOs.
3.3.2.2 Exceedances were
found for 1-hr average for NO2 in 2015 and exceedances of the annual
average NO2 were observed in the last 5 years.
3.3.2.3 Carbon Monoxide
(CO) has not been monitored at the Kwun Tong AQMS. The closest monitoring station with CO
monitoring data is at Mong Kok, which is a road side station. The latest 5 years of CO data, that is, 2015
to 2019, are summarised in Table 3.3 below,
with the CO data presented as 1-hour and 8-hours averages.
Table 3.3: CO Concentrations at EPD Mong Kok AQMS (2015 to 2019)
|
Pollutant |
Averaging Period |
Concentration (µg/m3) |
||||||
|
2015 |
2016 |
2017 |
2018 |
2019 |
5 Year Average |
Corresponding AQO |
||
|
CO |
Highest 1-hour Average (µg/m3) |
3410 |
2570 |
2390 |
2340 |
2280 |
2598 |
30,000 |
|
Highest 8-hour Average (µg/m3) |
2303 |
1911 |
2156 |
2041 |
2103 |
2103 |
10,000 |
|
3.3.2.4 Hourly
background concentrations of NO2, PM10, PM2.5, SO2, O3 and CO have, also, been
extracted from the EPD’s Pollutants in the Atmosphere and their Transport over
Hong Kong (PATH) 2016 model. PATH
model is set up on a three-dimensional grid system with horizontal
nesting. All the major emission sources
and meteorological information in Hong Kong, the PRD Region and other Mainland
areas outside the PRD region have been included in PATH model. Detailed emission sources adopted in the
PATH model can be found in Section 6 and 8 of EPD’s Guidelines for Local-Scale
Air Quality Assessment Using Models.
The Assessment Area is covered by the PATH grids (43, 32), (43, 33),
(44, 32) and (44, 33) as shown in Figure 3.1 and Table 3.4 below provides a summary of
the background levels from PATH, compared against the existing AQOs. The nearest year, that is, 2020, available
from the EPD’s website has been utilised.
Table 3.4 Background Concentrations from PATH Year 2020
|
Pollutant |
Corres- ponding AQO (μg/m3)(1) |
Value in
PATH Grid Cell (μg/m3)(3) |
|||
|
43_32 |
43_33 |
44_32 |
44_33 |
||
|
SO2 4th
highest 24-hour |
125 [3] |
26 |
25 |
26 |
22 |
|
SO2 4th
highest 10-min(2) |
500 [3] |
110 |
112 |
110 |
112 |
|
PM10 10th highest
24-hour |
100 [9] |
82 |
77 |
83 |
77 |
|
PM10 Annual |
50 |
38 |
34 |
41 |
34 |
|
PM2.5 10th highest
24-hour |
75 [9] |
62 |
57 |
62 |
58 |
|
PM2.5 Annual |
35 |
27 |
24 |
29 |
24 |
|
NO2 19th
highest 1-hour |
200 [18] |
132 |
121 |
131 |
122 |
|
NO2 Annual |
40 |
29 |
25 |
26 |
27 |
|
O3 10th
highest 8-hour |
160 [9] |
137 |
142 |
140 |
140 |
|
CO Maximum 1-hour |
30,000 |
1006 |
1,006 |
1,005 |
1,008 |
|
CO Maximum 8-hour |
10,000 |
836 |
836 |
839 |
840 |
Note (1):
Numbers in brackets [ ] denote the
number of exceedances allowed.
Note (2):
Conversion factors have been referenced from the “EPD’s Guidelines on the
Estimation of 10-minute Average SO2 Concentration for Air Quality in
Hong Kong” to convert the 1-hr average concentration of SO2.
Note (3): The
PATH background concentrations as presented in the table above do not include
the near-field impacts from the Tier 1 & 2 emission sources to the air
sensitive receivers.
3.3.2.5 With respect to
the future background air quality predicted by PATH in Table 3.4, all values are below the relevant AQOs.
3.4.1.1
The Assessment Area for the air quality impact
assessment is identified by a distance of 500m from the boundary of the Project
site and includes the relevant sensitive receivers taken from the list of
potential ASRs listed in the TM-EIAO, namely, domestic premises, hotels,
hostels, hospitals, medical clinics, nurseries, temporary housing
accommodation, schools, educational institutions, offices, factories, shops,
shopping centres, places of public worship, libraries, courts of law, sports
stadiums or performing arts centres.
3.4.1.2
Existing and planned ASRs within this 500m Assessment
Area have been identified with reference to the latest information provided on
the survey maps, topographic maps, aerial photos, land status plans and
confirmed by various site surveys undertaken.
3.4.1.3
With reference to the Kwun Tong (South) Outline
Zoning Plan (OZP) No. S/K14S/22, Ngau Tau Kok & Kowloon Bay OZP No. S/K13/30
and Kai Tak OZP No. S/K22/6, the existing ASRs comprise Government, Institution
or Community (GIC) uses, other specific uses (OU) and open space (O) etc. Details of the identified representative
ASRs are shown in Figure 3.1 and summarised in Table 3.5.
Table 3.5 Representative
Air Sensitive Receivers (ASRs)
|
ASR Description |
Assessment Point |
Landuse[1] |
Approximate Horizontal
Distance to Project Site Boundary (m) |
Building Height
Limit (mPD) |
Equipped with
Centralized Air-Conditioning System |
Location of Fresh Air
Intake |
|
Planned
Acute Hospital (Acute Building in Site A) |
ACU 1-17 |
G/IC |
Located under the
proposed helipad |
100 |
Y |
Under
detailed design [2][3] |
|
Planned Acute Hospital (Admin Building
in Site A) |
ADM 1-9 |
G/IC |
50 |
100 |
Y |
|
|
Planned Acute Hospital (Education Building
in Site A) |
EDU 1-13 |
G/IC |
190 |
100 |
Y |
|
|
Planned Acute Hospital (Oncology
Building in Site B) |
ONC 1-9 |
G/IC |
200 |
60 |
Y |
|
|
Planned Acute Hospital (SOPC Building
in Site B) |
SOP 1-9 |
G/IC |
320 |
60 |
Y |
|
|
Transport Department New Kowloon Bay
Vehicle Examination Centre (Planned Commercial Development cum EFLS Deport
and Station) |
ASR 1 |
G/IC |
115 |
40 |
N |
N/A |
|
Hong Kong Police Vehicle Detention and
Examination Centre Kowloon Bay |
ASR 2 |
G/IC |
260 |
40 |
N |
N/A |
|
Kai Tak Fire Station |
ASR 3, ASR 51-52 |
G/IC |
110 |
45 |
Y |
[2] |
|
Pacific Trade Centre |
ASR 4, ASR 53-55 |
C |
217 |
100 |
Y |
[2] |
|
Existing Kerry Dangerous Goods
Warehouse |
ASR 6, ASR 70 – 72 |
C |
250 |
100 |
N |
N/A |
|
Planned Residential Area at Cheung Yip
Street (Existing Citybus Kowloon Bay Parking Site) |
ASR 7, ASR 64 – 66 |
R |
155 |
100 |
N |
N/A |
|
Planned Residential Area at Shing Fung
Road |
ASR
9 |
R |
440 |
110 |
N |
N/A |
|
Planned Residential Area at Shing Fung
Road |
ASR 10 |
R |
410 |
120 |
N |
N/A |
|
Planned Residential Area at Shing Fung
Road |
ASR 11 |
R |
400 |
110 |
N |
N/A |
|
Planned Residential Area at Shing Fung
Road |
ASR 12 |
R |
420 |
95 |
N |
N/A |
|
Hong Kong Children’s Hospital |
ASR 33 – 50 |
G/IC |
80 |
60 |
Y |
[2] |
|
Enterprise Square Five |
ASR 15 |
OU |
330 |
170 |
Y |
[2] |
|
Manhattan Place |
ASR 16 |
OU |
330 |
170 |
Y |
[2] |
|
One Kowloon |
ASR 17 |
C |
430 |
170 |
Y |
[2] |
|
Yip On Factory Estate Block 1 |
ASR 18 |
OU |
360 |
120 |
N |
N/A |
|
Sunshine Kowloon Bay Cargo Centre |
ASR
19 |
OU |
350 |
120 |
N |
N/A |
|
Water Supplies Department Kowloon East
Regional Building |
ASR 20 |
G/IC |
370 |
60 |
Y |
[2] |
|
Fortune Industrial Building |
ASR 21 |
OU |
425 |
100 |
N |
N/A |
|
The Quayside |
ASR 22 |
OU |
360 |
100 |
Y |
[2] |
|
Manulife Tower |
ASR 23 |
OU |
440 |
100 |
Y |
[2] |
|
Transport
Department Kowloon Bay Vehicle Examination Centre |
ASR 24 |
G/IC |
200 |
40 |
N |
N/A |
|
Kowloon Bay Transfer Station |
ASR 25 |
OU |
230 |
40 |
N |
N/A |
|
Enterprise Square Three |
ASR 28 |
OU |
310 |
170 |
Y |
[2] |
|
Yip On Factory Estate Block 2 |
ASR 29 |
OU |
330 |
120 |
N |
N/A |
|
Commercial Building (under
construction) |
ASR 30 |
OU |
260 |
120 |
Unknown |
[2] |
|
Ngau Tau Kok Telephone Exchange |
ASR 31 |
G/IC |
430 |
40 |
N |
N/A |
|
Construction Industry Council Training
Academy Kowloon Bay Training Centre |
ASR 32 |
G/IC |
480 |
40 |
N |
N/A |
|
Kowloon Godown |
ASR 56 – 59 |
C |
290 |
100 |
N |
N/A |
|
Octa Tower |
ASR 60 – 63 |
C |
170 |
100 |
Y |
[2] |
|
Planned
Residential Area at Cheung Yip Street (Existing Public Works Central
Laboratory Building) |
ASR 67 – 69 |
R |
180 |
80 |
N |
N/A |
Note: [1]
R: Residential; OU: Other Specific Uses; G/IC: Government/ Institution and
Community; C: Commercial
[2]
The locations of fresh air intake were assumed to be at the highest, middle and
lowest height of the ASR for assessment purposes
[3]
The fresh air intake of the Acute Block will be designed to locate away from
the helipad as far as practicable in accordance to the requirements stated in
Federal Aviation Administration’s Advisory Circular for Heliport Design (https://www.faa.gov/documentLibrary/media/Advisory_Circular/150_5390_2c.pdf)
3.5.1.1 The proposed helipad will be located on the rooftop of the new Acute
Block of the NAH at about +119.15mPD in height. The anticipated construction period would
last approximately 12 months from Q4 2023 to Q4 2024. The helipad deck and associated
supporting structural frame would be constructed by aluminium/steel structure which
will be prefabricated off-site and assembles only at the site. Therefore, no significant excavation or
on-site construction would be undertaken and, therefore, stockpiling of
materials would be limited. Also,
only a negligible amount of construction and demolition (C&D) material will
be generated from the construction activities. In addition, there will be no off-site
works area or casting yard for this Project. No concreting works is required for this
Project.
3.5.1.2 Based on the above, the construction of the proposed helipad would not
be considered to cause significant dust impacts. In addition, only a limited amount of
equipment would be required for the helipad works including a tower crane and
welding set etc., and as such emissions from such equipment would not be
expected to be significant.
3.5.1.3 With the implementation of sufficient dust suppression measures as
stipulated under Air Pollution Control (Construction Dust) Regulation and Air
Pollution Control (Non-road Mobile Machinery) (Emission) Regulation, adverse air
quality impacts would not be anticipated.
3.5.1.4 Guidelines stipulated in EPD’s Recommended Pollution Control Clauses for
Construction Contracts should also be incorporated in the contract documents to
abate dust impacts.
3.5.1.5 As noted above, the helipad
one-year construction period would be between Quarter 4 of 2023 to Quarter 4 of
2024, with the proposed commissioning of the helipad in Quarter 4 of 2025. Key concurrent projects which may
contribute to any air quality impacts during the construction phase, as shown
in Table 2.6, would be the Central
Kowloon Route (CKR) – Slip Road S5, Trunk Road T2 and the NAH building
itself. As the construction works
of CKR and T2 are located at the ground level near the NAH and the separation
distances between the proposed helipad and these works are more than 100m, cumulative
impacts from these CKR and T2 works would be considered minimal. Given the major superstructure
construction works of the NAH building itself is estimated to be completed in
Q3 of 2023, it is anticipated that there would be no major construction works
of NAH remaining when the helipad construction commences and, therefore, the potential
for cumulative impacts from NAH is considered minimal.
3.6.1
Identification of Project Pollution Sources
Background
3.6.1.1 Potential air quality impacts during the operational phase of the
proposed roof helipad would be generated from the engine exhaust from the
helicopter using the facility.
Odour is not expected to be generated from the engine exhaust.
3.6.1.2 The proposed flight sectors will be in the north and south-to-east
directions. Figure 3.2 presents the
preliminary flight path of the Project.
Within the Assessment Area, the emissions from the operation modes associated
with the LTO cycles of the helicopter to be assessed are described below:
Non-lateral Movements
·
Hovering: Helicopter
turns on the spot over the helipad to achieve the desirable orientation for
touchdown / lift-off;
·
Touchdown: Helicopter
descends on the helipad surface;
·
Idling: Helicopter
remains on the helipad surface with its rotary blades kept running; and
·
Lift-off: Helicopter
ascends vertically from the helipad surface to achieve a hover before
departure.
Lateral Movements
·
Approach: Helicopter approaches
the helipad while it is descending at an angle to the helipad surface;
·
Take-off: Helicopter
leaves the helipad while it is climbing up at an angle to the helipad surface;
and
·
Flyover: Helicopter
cruises before approach or after take-off.
3.6.1.3 Difference operation modes will have different operational power and
duration and, hence, the emissions of each mode would be different. The non-lateral movements within the
helipad and the lateral movements of Approach and Take-off are located within
the assessment area and, hence, have been evaluated in this EIA.
3.6.1.4 The Flyover mode, however, will only occur outside the Assessment Area,
with typical flight height of this mode being more than 450mPD, which is greater
than 330m above the highest ASR (Acute Block) and, hence, would be considered
to have a negligible impact on the ASRs. Thus, the emissions from
the Flyover mode have not been assessed further.
3.6.2
Literature Review on Helicopter Emissions
Local Regulations/ Guidelines
3.6.2.1 In Hong Kong, the principal legislation to govern the air quality impact
is the Air Pollution Control Ordinance and its subsidiary Regulations as stated
in Section 3.2.3. AQO for 7 common
air pollutants as provided in Table 3.1
are met as soon as possible.
3.6.2.2 Apart from the AQO, The Hong Kong Planning Standards and Guidelines
(HKPSG) is a government manual of criteria for determining the scale, location
and site requirements of various land uses and facilities. As stated in Figure 2.2 of Chapter 9 of
HKPSG, the helipads are likely to cause significant noise concern (Type III)
whereas no specific classification of air quality concern from the helipads are
anticipated. (ref: https://www.pland.gov.hk/pland_en/tech_doc/hkpsg/full/pdf/ch9.pdf)
3.6.2.3 In addition, there is no local regulation
to govern the emissions of helicopter, as confirmed with GFS. The correspondence with GFS
is shown in Appendix
3A.
International Regulations/ Guidelines
3.6.2.4 An international literature review has been undertaken of helipads,
including helipads designated for emergency medical use, in other jurisdictions
to determine the importance and focus other countries place on the assessment
of air quality from such facilities.
3.6.2.5 Air ambulance helicopters, as they are termed in the United Kingdom
(UK), form an essential part of the UK’s pre-hospital response to patients
suffering life threatening injuries or illnesses. Based on this, the UK Civil Aviation
Authority (CAA) has published guidelines on “Standards for helicopter landing
areas at hospitals” (Civil Aviation Publication (CAP) 1264), August 2019, which
supersedes the previous guidelines presented in the Emergency Care Health
Building Note 15-03: Hospital Helipads, 2008. (http://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=7240).
3.6.2.6 The primary purpose of this UK guidance is to promulgate in detail the
design requirements and options for new heliports located at hospitals in the
United Kingdom and refurbishment of existing helicopter landing sites. The heliport design guidance provided is
based on international standards and recommended practices in the International
Civil Aviation Organisation (ICAO) Annex 14 Volume II. In terms of environmental issues, which
specifically focusses on noise, reference is made in the CAP to UK Circular
02/99 Environmental Impact Assessment (EIA) (https://www.gov.uk/government/publications/environmental-impact-assessment-circular-02-1999). The legislation (Section A25) is stated
in terms of the construction of airfields, as opposed to helipads, as follows:
“The
main impacts to be considered in judging significance are noise, traffic
generation and emissions. New permanent airfields will normally require EIA, as
will major works (such as new runways or terminals with a site area of more
than 10 hectares) at existing airports.
Smaller scale development at existing airports is unlikely to require
EIA unless it would lead to significant increases in air or road traffic”
(Annex A: Indicative Thresholds and Criteria for Identification of Schedule 2
Development Requiring EIA).
3.6.2.7 It is noted that helipads are not specifically included in these
requirements. While this Circular
02/99 was withdrawn in March 2014 and superseded with Town and Country Planning
(Environmental Impact Assessment) Regulations 2017 (http://www.legislation.gov.uk/uksi/2017/571/contents/made),
the requirements of the new legislations are similar, also legislating large
airfields with:
·
Schedule A projects in Section 7 (1)
defined as “Construction of lines for long‑distance railway traffic and of
airports with a basic runway length of 2,100 metres or more”; and
·
Schedule 2, Section 10(e) making
provisions for “Construction of airfields (unless included in Schedule 1),
where (i) The development involves an extension to a runway; or (ii) the area
of the works exceeds 1 hectare”.
3.6.2.8 Again, helipads are not included.
In CAP 1264, it is noted that, for a hospital landing site, the
occasions when helicopters could cause disturbance are likely to be irregular,
few in number and short in duration.
As a result, the guidance states that a formal noise analysis for hospital
heliports is unlikely to draw fully objective conclusions and may be of only
limited assistance to planning committees.
It is suggested by the CAP that any environmental impact is balanced
against the positive benefit for patients and for the community at large and
define some potential mitigation measures, as follows:
·
Locating the heliport on the highest
point of the estate, for example, on top of the tallest building;
·
Designing the flight paths to avoid
unnecessary low transits over sensitive areas;
·
Employing noise abatement flight paths
and using approach and departure techniques which minimise noise nuisance;
·
Dissipating noise using baffles formed
by intervening buildings and trees;
·
Insulating buildings and fitting double
glazing in vulnerable zones; and
·
Limiting night operations by
transporting only critically ill patients during unsociable hours (2300 to 0700
hours).
3.6.2.9 The CAP states that rooftop locations raise the helicopters’ approach
and departure paths by several storeys and reduce the environmental impact of
helicopter operations, in particular noise nuisance and the effects of downwash
at surface level. It can be concluded that the key aspects of the legislation
do not relate to helipads specifically or hospital helipads for emergency use
and that the environmental guidance is more focussed on noise issues than air
pollution.
3.6.2.10 In terms of legislation, regulations and guidance from the United States
of America (USA), the Federal Aviation Administration (FAA) issues a Code of
Federal Regulations (CFR) and Part 135 of the CFR regulates all commercial
on-demand, non-scheduled air flights, including helicopters (ref: https://www.ecfr.gov/cgi-bin/text-idx?SID=3f0ed9dc114fcaace3a3a89405bcb0d4&node=pt14.3.135&rgn=div5). However, the regulations
for all helicopters and their pilots pertain to safety and communications and
not environmental issues such as air quality.
3.6.2.11 Part 135.271 of the CFR defines regulations for Helicopter
Hospital Emergency Medical Evacuation Services and is relevant to safety issues
including flight and duty times, weather minimums and training of pilots (ref: https://www.ecfr.gov/cgi-bin/text-idx?SID=3f0ed9dc114fcaace3a3a89405bcb0d4&node=pt14.3.135&rgn=div5#se14.3.135_1271). Title 49
–Transportation of the CFR includes U.S. Code 44730 concerning Helicopter Air
Ambulance Operations, but this, also, refers to safety requirements, including
flight risk evaluations, and requires that Part 135 of the CFR should be
complied with.
3.6.2.12 In addition, Part 91 of the CFR details regulations for operations of
small non-commercial aircraft, setting out conditions which the aircraft may
operate, such as weather and is again focused on safety (ref: https://www.ecfr.gov/cgi-bin/text-idx?SID=d2269b706b9087958c603a2f5ecc4a35&mc=true&node=pt14.2.91&rgn=div5). However, this regulation
states that in an emergency requiring immediate action, the pilot-in-command
may deviate from any regulation contained within Part 91 to the extent required
to handle the emergency.
3.6.2.13 The FAA has, also, published an advisory circular (AC) which provides
information and guidance material specifically applicable to helicopter air
ambulance (HAA) operations (https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_135-14B.pdf). However, this AC relates to
certification, equipment, training, maintenance and overall safety and does not
cover environmental issues.
Notwithstanding, Section 3-9 Operations Under Special Conditions, Part
b, provides advice for nighttime operations which are, therefore, clearly
allowed for as part of HAA operations, with no environmental restrictions
defined.
3.6.2.14 In terms of air quality, however, the FAA does regulate emissions,
through the Engine Fuel Venting and Exhaust Emissions certification
requirements, including raw fuel vented to the atmosphere during normal engine
shutdown, and specifies the following products of combustion in aircraft engine
exhausts for certain classes of engines:
·
smoke
(SN);
·
hydrocarbons
(HC);
·
carbon
monoxide (CO); and
·
oxides
of nitrogen (NOx).
3.6.2.15 The Engine Fuel Venting and Exhaust Emissions certification requirements
(Title 14 of the CFR
Part 34) applies to civil airplanes that are powered by aircraft gas
turbine engines of the classes specified in the rule. However, under this regulation, it is
noted that “aircraft gas turbine engines” are defined as turboprop, turbofan or
turbojet aircraft engine which are not applicable to helicopters. In addition, Section 34.7 Exemptions,
Part (a) details exemptions based on flights for short durations at infrequent
intervals, with (4) stating an exemption for “Other flights the Administrator
determines, after consultation with the Administrator
of the EPA, to be for short durations at infrequent intervals”,
which would be appropriate to the emergency operations of the NAH helipad.
3.6.2.16 The ICAO does publish an “Airport Air Quality Manual” (https://www.icao.int/publications/Documents/9889_cons_en.pdf)
and this document contains advice and practical information for implementing
best practices with respect to airport-related air quality. It is noted that this document is
specifically relevant to airports and not individual helipads.
3.6.2.17 In terms of airport related emissions, this Manual covers aircraft
emissions, aircraft handling emissions, infrastructure or stationary-related
sources and vehicle traffic sources at airports. In respect of aircraft emissions, while
a helicopter can be defined as an “aircraft”, the ICAO Airport Air Quality
Manual specifies that the engine emissions standards are relevant to turbojet
and turbofan engines greater than 26.7 kilonewtons (kN) of thrust, but not to
turboprops, turboshafts, piston engines or aircraft auxiliary power units
(APUs) (Section 2.2.7). As
such, the emission standards in this Manual are not applicable to
helicopters.
3.6.2.18 The fact that air quality is not a key consideration for helipads and
specifically hospital helipads is, also, borne out by a review of recent
articles and literature as follows:
·
New
York City announced the “Improving Helicopter Safety Act of 2019” on 26 October
2019 (https://evtol.com/news/lawmakers-cite-noise-emissions-nyc-helicopter-ban/). The bill would prohibit “nonessential”
helicopters from flying over any U.S. city with a population of over 8 million
people and with a population density of over 25,000 people per square mile but
has exceptions for law enforcement, medical, emergency response, and other
“essential” flights in the public interest. Although safety was identified as the
primary impetus for the bill, Nadler and Velazquez also cited “incessant noise
pollution” as another reason for banning helicopter flights over the city. Air Quality was not a key factor.
·
A
24 hour helipad at King’s College Hospital in London was given approval to
operate 24 hours per day in 2019, after unanimous backing from Councillors (https://rosslydall.wordpress.com/2019/03/07/londons-first-24-hour-hospital-helipad-to-open-within-weeks-after-council-lift-off/). Seven residents were reported to have
objected to the plans, saying the noise would disturb their sleep. A noise report commissioned by the
hospital showed that World Health Organisation limits for sleep would be
breached for less than a minute at a time during take-off and landing and
concluded that noise levels would fall to “acceptable” levels if windows were
kept closed. Air Quality was not a
key factor in the deliberations or ultimate approval of the facility.
·
The
“Major Trauma Centres – Helicopter Landing Facilities Report”, March 2019 (https://associationofairambulances.co.uk/wp-content/uploads/2019/06/HLS-Report-MTN-March-2019-V1.pdf) provides details of
the quality and availability of hospital landing sites (HLSs) which are critical
for the efficient transportation of patients conveyed by air. From point of injury/illness to
receiving definitive in-hospital care is paramount and poor HLS availability
and capability will influence the patient journey to the detriment of the patient. Various factors dictate the location and
design of the HLS with safety and proximity to the trauma centre being the key
aspects and a focus on environmental noise above air quality.
3.6.2.19 Based on the reported benefits of locating helipads at trauma hospitals
in urban areas, specifically in the UK, there is a programme of expanding the
network of such facilities across the country, even being extended to 24 hour
operations, with the benefits over-riding any environmental issues. Also, in other jurisdictions, while
there is a move to restrict commercial and tourist helicopter movements from a
safety and noise perspective, essential and emergency helicopter flights are
being exempted. It is also noted
that air quality is not the key factor in either the approval of hospital
helipads nor the restriction of helicopter movements. Notably, helipads are not defined in the
UK EIA legislation as triggering the need for an EIA and FAA guidance relevant
to Helicopter
Hospital Emergency Medical Evacuation Services and helicopter air ambulance
(HAA) operations do not cover air quality or other environmental issues but
relate to safety aspects. In
addition, the ICAO guidance on air quality is relevant to airports specifically
and airplanes as opposed to helicopters.
3.6.3
Determination of Key Pollutants of Concern
3.6.3.1 Having reviewed the international guidelines/ practice above, air
quality is not considered as a key consideration for helipads and specifically
hospital helipads. In addition, the
impact of the emissions from the helicopter operations will be short-term, based
on the duration of the Landing and Take-off cycles (LTO) being only about 7
minutes as below, and the frequency of emergency helicopter operation is
expected to be very low.
·
Approach: within 60 sec.;
·
Hovering (Approach): within 5 sec.;
·
Touchdown: within 3 sec.;
·
Idling: 5 minutes;
·
Lift-off: within 3 sec.;
·
Hovering (Departure): within 5 sec; and
·
Take-off: within 60 sec.
3.6.3.2 The operation duration of the LTO cycles of the helicopter are short and
the duration of each of the operation modes of the LTO for the assessment are
listed above. The total time is approximately 7 minutes only and
correspondence with GFS confirming the operational mode and the approximate
operation duration is shown in Appendix
3A.
3.6.3.3 Table 3.6 below shows the total quantities of pollutants, namely SO2,
NOx and Particulates, for one helicopter flight. The emission rates of different
operation modes of the LTO cycles of the helicopter have been obtained by
reference to the “Guidance on the Determination of Helicopter
Emissions” issued by the Swiss Confederation in 2015. Detailed calculations are provided in Appendix 3B.
Table 3.6 Total
Quantity of Pollutant per Helicopter Flight
|
Pollutant |
Total Quantity
per Helicopter Flight (g) |
Averaged
Emission Rate per helicopter flight relative to AQO criteria (g/s) |
|||
|
10 mins |
1-hr |
24-hrs |
1-year |
||
|
SO2 |
257 |
0.4288 |
- |
0.0030 |
- |
|
NOx |
467 |
- |
0.1298 |
- |
1.5E-05 |
|
Particulates (RSP
and FSP) |
13 |
- |
- |
1.5E-04 |
4.0E-07 |
3.6.3.4 As shown in the 5-year air quality monitoring data in Table 3.2, exceedance of NO2
(annual) was recorded in the 2015-2019, whereas no exceedance of other major
pollutants, e.g. NO2 (1-hour) (except in Year 2015), SO2
(10-mins), RSP and FSP (24-hour and annual) was recorded. The emergency
helicopter movements are of short-term and infrequent nature. As revealed in Table 3.6 above, the
average emission rate per helicopter flight with duration at or longer than
1-hr AQO criteria is relatively low. As such, the emission impact for a period
of 1 hour or longer is expected to be minimal as over these longer periods air
pollutants in the ambient air would be largely dispersed and diluted. In addition, the helipad is located at
the rooftop of the Acute Block that has more than 100m away from the ground
level sensitive receivers, the impact from the emergency helicopter to these
sensitive receivers is expected to be very small. Hence, given the minor
emissions due to the non-scheduled, infrequent and short-term nature of the
emergency helicopter movements, the large distance to the ground level
sensitive receivers and the large margin from AQO for NO2 (1-hour),
SO2 (24 hours) and RSP and FSP (24 hours and annual) of the ambient
air quality, it is not anticipated that the Project would cause AQO exceedance
for these parameters, and further quantitative assessment for these parameters
is considered not necessary.
3.6.3.5 Thus, 10-minute average SO2 concentration AQO has been quantitatively
assessed in the operational air quality impact assessment. The key pollutant from the marine
emission is SO2. Due to
the implementation of the new air quality improvement measures, SO2
from marine emission would be reduced in the future. As conservative approach, PATHs
concentration output for Year 2020 are adopted since the proposed helipad is to
be operated in Year 2025.
3.6.4
Measures and Alternatives Considered to Avoid and Minimise Air Pollution
Location of Helipad
3.6.4.1 As revealed in Section 2.2.2,
the helipad is located above the rooftop of Acute Block at 119.15mPD which is
higher than the nearest planned sensitive receiver R(B)2 (ASR 7) nearby in
order to minimise the air pollution effects. In addition, the helipad location
selected is at the west corner of Acute Block which is located as far away as
possible from the planned ASR R(B)2 (ASR 7).
Air
Quality Enhancement Measures for Helicopter NOx Emissions
3.6.4.2 As detailed in Section 3.6.3.4,
exceedances of the annual average NO2 have been observed in the last
5 years in the Assessment Area. Although
the background level of average annual NO2 is high, the helicopter
flight to the proposed helipad would be for medical emergency purpose. Furthermore, the helicopter flight would
be short-term, infrequent and non-scheduled (likely less than 1 trip per day on
average). As such, the contribution
of NO2 due to the operation of the proposed helipad would be
minimal.
3.6.4.3 Despite the proposed helipad does not form an integral part of the Acute
Block of the NAH, as the project proponent of both the subject helipad and the hospital, HA
will review the air quality issue within the proposed NAH project. A key portion of
the NO2 emissions from the NAH project will be generated from
vehicles utilising the hospital complex. Apart from visiting vehicles to
the hospital by external parties, there are certain number of hospital-owned
vehicles serving the hospital’s day-to-day operational needs. These
include private vehicles, goods vehicles, and non-emergency ambulance transfer
service (NEATS) vehicles which provide a free, point-to-point transfer services
for patients at times of admission, transfer to another hospital, discharge,
and follow-up visits for outpatient specialist services. While generally
speaking the NEATS serves all public from within the entire Hong Kong regions, majority
of the service will cover the nearby districts including Kowloon City, Wong Tai
Sin, Kwun Tong and Yau Tsim Mong. In order to enhance the air quality in the vicinity of the Project, HA would provide 5 nos. of electric light buses to replace the diesel NEATS
light buses.
3.6.4.4 As HA and the end user Kowloon Central Cluster is in the process of
formulating the entire operational fleet at the time of reporting, this
enhancement measure could be eventually accomplished by any combination of
electric vehicles (with better or equivalent performance of the electric light
buses) with the review of latest electric vehicles technology before the
operation of the helipad.
3.6.4.5 In addition, NAH will also take chance to improve the pedestrian
connectivity for enhancing the walkability in and around the campus and
incorporating NOx-neutralising pavers as much as practicable (approximate 780m2
of NAH), so that the NOx emissions generated from vehicles in the vicinity of
the site can be further reduced as much as possible. The location of proposed
neutralising paver is provided in Appendix 3D.
With the above-mentioned air quality
enhancement measures in place, it is anticipated any adverse NO2
impact by the Project could be avoided.
3.6.5
Cumulative Air Quality Impacts of Helicopter SO2 Emissions
Background
3.6.5.1 In order to assess the cumulative SO2 air quality impacts,
pollutant emitting activities within the Assessment Area of the NAH helipad have
been identified and reviewed and include the following sources. The locations of potential cumulative
sources are shown in Figure 3.3.
Emissions
from NAH Chimneys
3.6.5.2 Three chimneys are proposed for the New Acute Hospital, two of which are
located on Administration Block (Block B), while one is located on the
Specialist Out-patient Clinic (SOPC) Block building (Block E). The chimneys are connected to 2-3
boilers with 1 standby boiler. Under
the current design, solar hot water panels and energy efficient heat pumps which
are supplied by electricity will be the primary source of steam and hot water
generation for the hospital. Towngas
and diesel boilers will be adopted as back-up/ reserve outputs only.
3.6.5.3 Given that the application of solar hot water panels and heat pumps are supplied
by electricity which is environmentally friendly, no SO2 emissions
from the proposed design are anticipated.
In addition, as Towngas is classified as a clean fuel with ultra-low sulphur
content, and the use of diesel will be an emergency backup fuel for the
proposed boilers only, the potential SO2 emissions from the NAH
chimney are considered to be negligible.
Emissions
from Nearby Chimneys
3.6.5.4 A chimney survey within the 500m Assessment Area was undertaken in
December 2019 and relevant EIA studies, including the Kai Tak Development
(AEIAR-130/2009) and Kai Tak Multi-purpose Sports Complex (AEIAR-204/2017),
have been reviewed. Based on the survey
and literature review, one chimney at the Training Authority Clothing
Industrial Kowloon Bay Training Centre and three chimneys at the Hong Kong
Children’s Hospital have been identified within the 500m Assessment Area.
3.6.5.5 According to the latest information obtained from the operator, the
chimney opening at the Training Authority Clothing Industrial Kowloon Bay
Training Centre has been blocked by a steel cover and is no longer in use. The relevant correspondence is provided in
Appendix 3E.
3.6.5.6 According to the information provided by Hospital Authority, the three
chimneys at the Hong Kong Children’s Hospital are connected to 3 boilers with 1
standby boiler. Towngas is used as
the primary fuel and diesel is designated as the emergency backup fuel for the
boilers. As Towngas is classified
as a clean fuel with ultra-low sulphur content, the SO2 chimney
emissions would be considered to be negligible and this source is, therefore,
not assessed further. The relevant correspondence is provided in Appendix
3F.
Vehicular
Emissions
3.6.5.7 In Hong Kong, with the introduction of the ultra-low sulphur fuel for
road vehicles, SO2 emissions from road transport has become
insignificant and considered to be negligible. Besides, the vertical separation distance
between the helipad and road vehicles will be over 110m. The potential for cumulative impacts
from the road transportation in terms of SO2 is, therefore,
considered to be minimal.
Marine
Emissions
3.6.5.8 In terms of marine emissions, the Kwun Tong Typhoon Shelter vessel is
located outside the 500m Assessment Area.
The other marine facilities in the area such as the Kwun Tong Ferry
Pier, Kwun Tong Dangerous Goods Vehicular Pier, Kwun Tong Public Pier and
Runway Park Pier are all outside the 500m Assessment Area.
3.6.5.9 In addition, the police moorings buoys, located along the eastern edge
of the former runway are also located outside the 500m Assessment Area (Figure
3.3).
3.6.5.10 However, two barging facilities are located in this water body, along
the seawall of the previous Kai Tak airport apron (Figure 3.3). One will be utilised during the
construction of the Trunk Road T2 project and according to the latest
information obtained from CEDD, the barging point will be operational until Q3
2025 (Appendix
3G). Based on site
observations, there is, also, a barging facility, comprising one barge and one
tugboat, for a recycling centre located next to the Kerry Dangerous Goods
Warehouse (Kowloon Bay). Based on
the above, these two barging facilities have been included as cumulative SO2
emission sources during the Project operational phase. The detailed
calculations of the emission factors of these two barging facilities are
provided in Section 3.6.6 below.
Other
Helicopter Emissions
3.6.5.11 A Government Flying Services (GFS) Kai Tak Division (GFS KTD) facility is
planned at the tip of the ex-Kai Tak Runway, which is about 1.5km to the
south-east of the NAH site. GFS
have confirmed that the flight paths of the proposed helipad and the GFS KTD
would not overlap with each other concurrently for flight safety reasons. Communications between helicopters and
the GFS control base will be on-going throughout all flight operations to
ensure the availability of flight paths.
Hence, cumulative helicopter emissions from the GFS Kai Tak Division
within the Assessment Area are not anticipated.
Other
Major Emission Sources within 4km
3.6.5.12 In order to account for the spatial variations in background
concentrations, major SO2 major point emission sources within 4km of
the Project boundary have, also, been reviewed. Two point sources, including the
chimneys of Diamond Hill Crematorium in Diamond Hill, and the Cruise Terminal
in Kai Tak, have been identified as major sources of SO2 emissions
and have been included in the assessment.
There is a major emission source located within the 4km of the Project
boundary, that is, the Ma Tau Kok Gas Plant. However, according to the latest SP
License obtained, the SO2 emission would be emitted during emergency
event, therefore, it is not assessed further. The locations of these major
emission sources within 4km are shown in Figure 3.4.
The relevant
correspondence with the operator (i.e. Towngas) is provided in Appendix
3H.
3.6.5.13 The emission factor of Diamond Hill Crematorium has been reviewed with
reference to the Specified Process Register No. E-24-007, with the SO2
emission source being the emergency generator and the relevant correspondence
with Food and Environmental Hygiene Department (FEHD) is provided in Appendix
3H. Considering the
generator would only be operating during emergencies and not reflect the normal
operating situation, this emission source has not been taken in account in the
cumulative impact assessment.
3.6.5.14 The emission factors from Kai Tak Cruise Terminal has been reviewed with
reference to the previous approved EIAs including the Kai Tak Development
(AEIAR-130/2009) and Kai Tak Multi-purpose Sports Complex (AEIAR-204/2017) and
the latest information reviewed. The
detailed calculations of the emission factors are provided in Section 3.6.6 below.
General Approach on Helicopter Emissions
Background
3.6.6.1 In accordance with the “Guidelines on Choice of Models and Model
Parameters”, issued by EPD, AERMOD is a steady state Gaussian plume model and is
one of the prescribed models for use to assess pollutant concentrations from
sources associated with non-road type and point sources, that is, the
helicopter and chimney emissions.
3.6.6.2 The engine exhaust from the helicopter is the only air pollution source
for the proposed helipad during the operational phase. SO2 is the
major pollutant from the helicopter operations to be quantitatively assessed (Section 3.6.3), with vehicular emissions
and chimney emissions from NAH and Hong Kong Children’s Hospital anticipated to
have negligible contributions to overall SO2 concentrations.
3.6.6.3 The methodology for assessing the SO2 concentrations from the
helicopter operations, and the relevant cumulative emission sources detailed in
Section 3.6.5 above, during the
operational phase, is outlined in the sections below.
3.6.6.4 The proposed flight sectors will be in the north and south-to-east
directions. Figure 3.2 presents the preliminary flight path of the Project. Within the Assessment Area, the emissions
from the operation modes associated with the LTO cycles of the helicopter to be
assessed.
3.6.6.5 The proposed helipad is for medical emergencies only. According to the
previous record for the number of emergency helicopter operations between 2015
and 2019, the average daily emergency helicopter operation would be less than
one, with the highest annual emergency helicopter landings being at the Pamela
Youde Nethersole Eastern Hospital (PYNEH) in 2017. The flight records reflect that the
average daily emergency helicopter landing was less than one, with emergency
helicopter landings in the daytime period being about once every one to two
days on average. Also, the evening
and night-time emergency helicopter landings at the PYNEH were one flight every
ten days and eight days respectively on average as shown in Table 5.7 of the noise chapter.
3.6.6.6 The proposed helipad at the NAH, together with the planned helipad at Queen
Mary Hospital (QMH) upon its completion, shall share the existing number of
helicopter landings and, thus, the flight frequency at the PYNEH would be
reduced in future. Also, it is
expected that the flight frequency at NAH would not be higher than the existing
flight frequency at the PYNEH, conservatively.
Air Pollutant Emission Rates
3.6.6.7 The SO2 emission factors for the helicopter operations are
presented in Appendix 3B.
Assessment Methodology and Assumptions
3.6.6.8 AERMOD has been used for the assessment of the SO2 pollutant
concentrations for this non-road type source.
3.6.6.9 According to the details in Figure 3.2, there are three major flight sectors, two for the north sector and one
for the south-to-west section.
Three pairs of models, that is, 1 flight sector with 2 flight paths in
each pair of model have been assessed to predict the highest emission impacts
from the helicopter operations.
3.6.6.10 In accordance with the EPD’s “Guidelines on the Estimation of 10-minute
Average SO2 Concentration for Air Quality Assessment in Hong Kong”,
the stability-dependent multiplicative factors are extracted in Table 3.7.
Table 3.7 Stability Conversion Factor
|
|
Stability Class |
|||||
|
|
A |
B |
C |
D |
E |
F |
|
Conversion Factor |
2.45 |
2.45 |
1.82 |
1.43 |
1.35 |
1.35 |
General Approach on Marine Emissions within 500m
Assessment Area
3.6.6.11 For the Trunk Road T2 barging facility, the number of barges and the
operation details has been obtained from the Project Engineer (Appendix 3I).
3.6.6.12 For the recycling centre barging facility, based on a conservation with
the Operator, there is an intention to relocate the recycling centre but no
schedule can be confirmed. Therefore,
in order to assess a worst-case scenario, this barging facility has been included
in the cumulative assessment for SO2.
3.6.6.13 The detailed calculated emission factors of these two barging facilities
are provided in Appendix 3J.
General Approach on Other Major Emission Sources
within 4km
3.6.6.14 There is one major point source emission source within 4km from the
Project which is the cruise hotelling emission from cruise terminal. The emission factors of the cruise
terminal have been identified based on a review of relevant information and the
latest cruise schedule obtained from the Kai Tak Cruise Terminal.
3.6.6.15 According to the latest cruise schedule from 2020 to 2023, the highest
number of scheduled cruise liners visiting Hong Kong will be in the Year 2021
and, hence, the cruise liner type in 2021 has been reviewed. As presented in Appendix 3K, “World Dream” has the
highest frequency of visit to Hong Kong, comprising greater than 50% of the
total cruise liner schedule for 2021.
Therefore, emissions from the “World Dream” liner has been adopted for this
EIA assessment. Given there are two
berthing spaces at the Cruise Terminal, another cruise liner with a higher
engine power and longer length than the World Dream vessel has been identified
as detailed in Appendix 3K. Spectrum of the Seas / Ovation of the
Seas under the same owner, Royal Caribbean Cruise Ltd., has a longer length vessel
than “World Dream” and, has therefore been selected as the second cruise liner
for hotelling at the same time as “World Dream” for a worst case assessment. The emission factors of these cruise
ships utilising the Kai Tak Cruise Terminal are presented in Appendix 3L.
3.6.6.16 The emission factor of SO2 is proportional to the Sulphur
content in the fuel. According to Air Pollution Control (Fuel for Vessels)
Regulation, the fuel sulphur content is restricted to 0.5% starting from 1
January 2019. According to the latest information obtained from the Kai Tak Cruise
Terminal (see correspondence in Appendix 3M), the same fuel is
supplied to both local and ocean going vessels at the Cruise Terminal and, as
the requirement for local vessels is set at <0.05% sulphur content, the fuel
supplied at the Kai Tak Cruise Terminal complies with this more stringent
requirement. It is confirmed by the
Kai Tak Cruise Terminal that the sulphur content of the bunker fuel for sale at
the Kai Tak Cruise Terminal has, therefore, generally got a sulphur content of
~0.03%, far lower than the legal requirement for ocean going vessels.
3.6.6.17 In addition, according to the EPD AQO review in 2019, Ocean-going
vessels (OGVs) at berth will be required to use marine diesel with a lower fuel
sulphur content not exceeding 0.1%. (https://www.legco.gov.hk/yr18-19/english/panels/ea/papers/ea20190325cb1-723-3-e.pdf). This requirement will be adopted in
short term and before the operational phase of the proposed helipad in
2025. Hence, a correction factor of
0.2 (=0.1/0.5) has been adopted for the hotelling mode, as detailed in Table 3.8 below.
Table 3.8 Kai
Tak Cruise Terminal Emissions Data
|
Pollutants |
Emission Rate (g/s) |
|
|
Hotelling Mode |
||
|
Cruise Liner – World Dream |
Cruise Liner – Spectrum
of the Seas / Ovation of the Seas |
|
|
SO2 |
1.20 |
1.07 |
[1] Hotelling mode includes one hour hotelling operations in a one-hour
period.
3.6.6.18 AERMOD has been used for the assessment of the pollutant concentrations
for this non-road type source.
Meteorological Conditions
3.6.6.19 The WRF meteorological data for the latest year 2010 and extracted from
the PATH model for grids covering the Assessment Area, that is, grids (43, 32),
(43, 33), (44, 32) and (44, 33), have been processed by AERMET modelling, the
meteorological pre-processor of AERMOD, into the format that can be employed in
the AERMOD dispersion model.
3.6.6.20 Surface characteristic parameters such as albedo, Bowen ratio and
surface roughness are required in the AERMET model. In accordance with the USEPA’s
AERMOD Implementation Guide, albedo and Bowen ratio should be determined by
10km by 10km region. The land use
characteristics of each relevant PATH-2016 grids (43, 32), (43, 33), (44, 32)
and (44, 33) have been classified into sectors and the parameters of each
sector calculated by using default values suggested by AERMET, according to these
land use characteristics. The
detailed assumptions are presented in Appendix 3N.
Representative Air Quality Impact Assessment Points
3.6.6.21 The Acute Block of the new Kai Tak Hospital is in close proximity to the
proposed helipad and is anticipated, therefore, to have the highest air quality
impacts from the operation of the Project.
Nevertheless, the identified ASRs, as shown in Table 3.5, have been assessed in order to determine the helicopter
emissions within the flight paths shown in Figure 3.2. Therefore, assessment points
have been adopted at the lowest, middle and highest levels of the identified
ASRs.
Noise Barrier Assumptions
3.6.6.22 As detailed in Section 5,
noise mitigation measures in the form of a vertical noise barrier, combined
with noise reducers, are proposed.
The proposed noise barrier is at a relatively higher level, 4.9m above
the helipad, +123.9mPD. Both “with
barrier” and “without barrier” scenarios have been assessed. The AERMOD input parameters of both
helicopter and marine emissions are provided in Appendix 3O.
3.6.7
Operational Phase Air Quality Impact Assessment Results
Results
3.6.7.1 The potential cumulative air quality impacts for SO2 at the
ASRs during the operational phase, including the helicopter and marine emissions
were assessed. The worst SO2
concentrations among the 3 flight paths for each scenario are shown in Table 3.9 below. The detailed breakdown of the air quality
impact assessment results is provided in Appendix 3P. Figures 3.5 – 3.7 presents the contour
plotting of the cumulative impacts of the combined helicopter and the marine
emissions at the worst assessment height. In order to assess a
worst-case scenario, the highest SO2 concentration between 2 scenarios (i.e. “with barrier” and
“without barrier” scenarios) at each point for contour were selected to plot contour.
Table 3.9 Cumulative
Assessment Result during Operational Phase
|
ASR
Description |
Assessment
Point |
Assessment
Level |
Maximum SO2
(10-mins) (µgm-3) |
|
|
Without Barrier |
With Barrier |
|||
|
Criteria |
500
µgm-3 |
|||
|
Planned
Acute Hospital (Acute Building in Site A) |
ACU
1-17 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
159 |
159 |
||
|
Planned
Acute Hospital (Admin Building in Site A) |
ADM
1-9 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
130 |
130 |
||
|
Planned
Acute Hospital (Education Building in Site A) |
EDU
1-13 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
141 |
141 |
||
|
Planned
Acute Hospital (Oncology Building in Site B) |
ONC
1-9 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Planned
Acute Hospital (SOPC Building in Site B) |
SOP
1-9 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Transport
Department New Kowloon Bay Vehicle Examination Centre (Planned Commercial
Development cum EFLS Deport and Station) |
ASR
1 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Hong
Kong Police Vehicle Detention and Examination Centre Kowloon Bay |
ASR
2 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Kai
Tak Fire Station |
ASR
3, ASR 51-52 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Pacific
Trade Centre |
ASR
4, ASR 53-55 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
133 |
133 |
||
|
Existing
Kerry Dangerous Goods Warehouse |
ASR
6, ASR 70 – 72 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
148 |
148 |
||
|
Planned
Residential Area at Cheung Yip Street (Existing Citybus Kowloon Bay Parking
Site) |
ASR
7, ASR 64 – 66 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
163 |
163 |
||
|
Planned
Residential Area at Shing Fung Road |
ASR
9 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
155 |
155 |
||
|
Planned
Residential Area at Shing Fung Road |
ASR
10 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
134 |
134 |
||
|
Planned
Residential Area at Shing Fung Road |
ASR
11 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
184 |
184 |
||
|
Planned
Residential Area at Shing Fung Road |
ASR
12 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
215 |
215 |
||
|
Enterprise
Square Five |
ASR
15 |
Lowest |
112 |
112 |
|
Middle |
124 |
124 |
||
|
Highest |
112 |
112 |
||
|
Manhattan
Place |
ASR
16 |
Lowest |
112 |
112 |
|
Middle |
121 |
121 |
||
|
Highest |
112 |
112 |
||
|
One
Kowloon |
ASR
17 |
Lowest |
112 |
112 |
|
Middle |
119 |
119 |
||
|
Highest |
112 |
112 |
||
|
Yip
On Factory Estate Block 1 |
ASR
18 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
120 |
112 |
||
|
Sunshine
Kowloon Bay Cargo Centre |
ASR
19 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Water
Supplies Department Kowloon East Regional Building |
ASR
20 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Fortune
Industrial Building |
ASR
21 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
The
Quayside |
ASR
22 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Manulife
Tower |
ASR
23 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
123 |
123 |
||
|
Transport
Department Kowloon Bay Vehicle Examination Centre |
ASR
24 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Kowloon
Bay Transfer Station |
ASR
25 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Enterprise
Square Three |
ASR
28 |
Lowest |
112 |
112 |
|
Middle |
119 |
119 |
||
|
Highest |
112 |
112 |
||
|
Yip
On Factory Estate Block 2 |
ASR
29 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
125 |
114 |
||
|
Commercial
Building (under construction) |
ASR
30 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
115 |
112 |
||
|
Ngau
Tau Kok Telephone Exchange |
ASR
31 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Construction
Industry Council Training Academy Kowloon Bay Training Centre |
ASR
32 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Hong
Kong Children’s Hospital |
ASR
33 – 50 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
112 |
112 |
||
|
Kowloon
Godown |
ASR
56 – 59 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
131 |
131 |
||
|
Octa
Tower |
ASR
60 – 63 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
147 |
147 |
||
|
Planned
Residential Area at Cheung Yip Street (Existing Public Works Central Laboratory
Building) |
ASR
67 – 69 |
Lowest |
112 |
112 |
|
Middle |
112 |
112 |
||
|
Highest |
122 |
122 |
||
Mitigation Measures
3.6.7.2 As detailed above, the operational air quality assessment for SO2
(10-mins) has concluded that there will be no predicted exceedances of the
relevant AQO at any of the representative ASRs and no mitigation measures are
required.
3.7.1.1 With the implementation of good site practices during the construction
phase, no adverse air quality impacts would be predicted and no significant residual
impacts are anticipated.
3.7.1.2 During the operational phase, no adverse air quality impacts are
predicted due to the limited use of helicopter and no adverse residual impacts
are anticipated.
3.8.1.1 The assessment has concluded that no adverse impacts during the
construction and operational phases would be predicted. However, regular site
inspection and audit of at least once per week are recommended to ensure good
site practices are being effectively implemented. Details of the Environmental
Monitoring and Audit (EM&A) requirements and mitigation measures are
provided in the stand-alone Project EM&A Manual.
3.9.1.1 Potential air quality impacts from the construction works for the
Project would mainly be related to emissions from construction equipment. With the implementation of sufficient
dust suppression measures as stipulated under Air Pollution Control
(Construction Dust) Regulation and Air Pollution Control (Non-road Mobile
Machinery) (Emission) Regulation, adverse air quality impacts would not be
anticipated.
3.9.1.2 In respect of the operational phase of the Project, based on cumulative
impacts of the helicopter and marine emissions, no exceedances of the SO2
(10-mins) AQO are predicted and no adverse operational phase impacts are expected
to occur.
3.9.1.3 Given the minor emissions due to the non-scheduled, infrequent and
short-term nature of the emergency helicopter movements, and the large margin
from AQO for NO2 (1-hour), SO2 (24-hour) and RSP and FSP
(24 hours and annual) in the local area, it is not anticipated that the Project
would cause AQO exceedance for these parameters. That said, air quality enchantment
measures, including the use of electric vehicles and NOx-neutralising paver,
would be incorporated in the design of NAH to enhance air quality in the
vicinity of the Project. With the
air quality enhancement measures in place, it is not anticipated that the
Project would cause adverse air quality impact at the nearby air sensitive
receivers.