11.1.1.1
This
section presents the baseline fisheries conditions within the Assessment Area,
and the assessment results of the potential fisheries impacts resulting from
the construction and operation of the Project.
The location plan and description of the Project are presented in Figure 1.1 and Chapter 2 respectively.
11.1.1.2
According
to the EIAO-TM, baseline conditions for fisheries resources were evaluated
based on information from available literature and site visits conducted for
the purposes of this EIA. Measures
required to mitigate any identified adverse impacts are recommended, where
appropriate, and residual impacts are assessed.
11.1.2
Structure of the Fisheries Impact Assessment
11.1.2.1
The
remainder of this Fisheries Impact Assessment section is organised as follows:
·
Section 11.2 introduces the criteria and
guidelines related to the impact assessment for this Project
·
Section 11.3 provides
the assessment approach and methodologies undertaken to evaluate the fisheries
resources to be impacted by the Project
·
Section
11.4
presents the baseline information of fisheries resources within the Assessment
Area
·
Section
11.5
predicts the potential fisheries impacts arising from the Project, and
evaluates the significance of each of these identified potential impacts
·
Section
11.6
presents the cumulative impact due to Project and concurrent projects within
the Assessment Area
·
Section
11.7
provides information on proposed mitigation measures to avoid, minimize and
compensate for the adverse impacts identified
·
Section
11.8
identifies the potential residual impacts arising from the Project
·
Section
11.9
presents the need and the details of a monitoring and auditing programme for
the Project
·
Section
11.10
summarises the key findings and recommendation from the Fisheries Impact
Assessment chapter.
11.2.1.1
This
fisheries impact assessment makes reference to the
following HKSAR Government ordinances, regulations, standards, guidelines, and
documents when identifying the importance of fisheries resources, and
evaluating and assessing potential impacts arising from the Project:
·
Environmental Impact
Assessment Ordinance (EIAO) (Cap. 499)
·
Technical Memorandum on
Environmental Impact Assessment Process (EIAO-TM) Annexes 9 and 17
·
Water Pollution Control
Ordinance (Cap. 358)
11.3.1.1
In
accordance with the EIA Study Brief No. ESB-340/2021, the Assessment Area for fisheries
impacts includes areas within 500 metres from the boundary of the Project and
associated works, and other areas that would be potentially impacted by the
construction or operation of the Project. Special attention is also given to pond
culture resources and activities, as well as any watercourses which may serve
as water sources for the fishpond areas (Figure 11.1 refers).
11.3.1.2
Literature
review and desktop study were conducted to collate the latest baseline
conditions regarding fisheries resources within the Assessment Area, which
includes sources of information such as:
·
Agriculture, Fisheries
and Conservation Department (AFCD) Annual Reports;
·
AFCD website on aquaculture;
·
AFCD website on oyster culture;
·
AFCD website on Accredited
Fish Farm Scheme;
·
Report of the Committee
on Sustainable Fisheries (2010);
·
EIA Report for Development
of Lok Ma Chau Loop – EIA Report (AEIAR-176/2013) (CEDD & PlanD, 2013a);
·
EIA Report for North East New Territories New Development Areas Planning
and Engineering Study – Investigation – EIA Report (AEIAR-175/2013) (CEDD &
PlanD, 2013b);
·
Proposed Comprehensive
Development at Wo Shang Wai, Yuen Long – EIA Report (AEIAR-120/2008) (Profit
Point Enterprises Ltd, 2008);
·
Hong Kong Section of
Guangzhou-Shenzhen-Hong Kong Express Rail Link – EIA Report (AEIAR-143/2009)
(MTRC, 2009); and
·
Recent aerial photos.
11.3.1.3
The
baseline conditions established from desktop study were considered relevant to
the current assessment. Nonetheless, in order to obtain the latest site-specific information, site
visits were also conducted for the verification of the ponds and associated
fisheries activities, where accessible.
Site visits were conducted between November 2021
and October 2022. The conditions of
the fishponds and the fisheries activities were observed and recorded. Interview was also conducted with the
representatives/members of Hong Kong New Territories Fish Culture Association
(HKNTFCA) to obtain further information on the local pond fisheries. The baseline information on fishpond
conditions were further reviewed based on relevant information provided by AFCD.
11.3.2.1
General
activity status of the fishponds was categorised as follows:
·
Active: currently utilised for commercial aquaculture
activities (described in Section 11.3.2.2), including commercial fishponds, fish fry ponds, and
indoor fish farms;
·
Inactive: no current commercial aquaculture activities and
management (e.g. overgrown vegetation at pond bunds which hindered culture
activities, and lack of equipment such as aerator), but no major physical
constraints to its resumption in the short-term, including fishponds with fish
present in non-commercial quantities and ponds for recreational fishing;
·
Abandoned: ponds in which there was physical evidence that
aquaculture has not been practised for years (typically ponds with overgrown
vegetation or dried up) and/or where there are obvious physical constraints to
the resumption of fisheries activities (e.g. inaccessible or fenced off);
·
Others: ponds that were unrelated to commercial aquaculture
activities, including concreted ornamental ponds, ponds created for wetland
compensation or ecological enhancement, flood storage ponds, or wastewater
treatment, etc. These “other ponds” were
irrelevant to fisheries impacts and were scoped out from further
assessment.
11.3.3
Assessment Approach
11.3.3.1
The
criteria and guidelines set out in Annexes 9 and 17 of the EIAO-TM were
followed to evaluate and assess the impact of Project construction and
operation on the fisheries resources. The
coverage of the fisheries resources concerned shall include but not limited to
aquaculture sites, culture activities, production, aquaculture potential,
etc. Potential direct / indirect,
on-site / off-site, primary, secondary, cumulative and
residual fisheries impacts arising from the construction and operation of the
Project were identified and evaluated.
Mitigation measures as well as environmental monitoring and auditing
programme were recommended, where necessary.
11.4.1
Description of Physical Environmental Background
Aquaculture (Pond Fish Culture)
11.4.1.1
Within
the Assessment Area, an extensive area of fishponds was identified at the
northern portion (north of San Tin Highway), including areas such as Lok Ma
Chau and San Tin. Smaller fishponds were
also identified to the south, mainly at Shek Wu Wai and Ngau Tam Mei. Pond fish culture of various activity
statuses were identified, which include active, inactive, and abandoned
fishponds (refer to Figure 11.1A to 11.1I).
Other Fisheries Resources
11.4.1.2
No
other fisheries resources such as capture fisheries, other aquaculture (oyster
culture and Fish Culture Zones) and sites of fisheries importance (Artificial
Reef) were recorded within the Assessment Area.
The nearest oyster culture area (outside the Assessment Area) is located
about 5.9 km west of the Project site in Deep Bay Water Control Zone (WCZ),
while no capture fisheries, Fish Culture Zones and Artificial Reef were
identified within Deep Bay WCZ.
Considering the absence of these other fisheries resources, potential
impacts on these resources are not anticipated.
Detailed information on these resources is scoped out from the remainder
of this chapter.
Sam Po Shue Wetland
Conservation Park (SPS WCP)
11.4.2
Pond Fish Culture Activities and Resources
Desktop Study
11.4.2.2
According
to AFCD (2023a), local inland fishponds covered approximately 1,129 ha in 2022. These ponds produced 2,073 tonnes of
freshwater fish amounting to HK$55 million.
Fisheries production from the local fishponds accounted for about 4% of
the total local freshwater fish consumption in 2020 (AFCD, 2021).
11.4.2.3
The vast majority of these farms engaged in carp polyculture and farmed species such as
Bighead Carp, Grass Carp, Common Carp and Silver Carp in combination with
Tilapia or Grey Mullet. Small portion (about 8%) of pond
fish culture in Hong Kong involve monoculture of carnivorous species such as
giant groupers, seabreams, and spotted scats at brackish fishponds near the
coastline (AFCD, 2023a). The aquaculture
species Jade Perch (Scortum barcoo) was introduced by AFCD to the local fisheries
industry (AFCD, 2011). Since 2010, AFCD
has mastered the induced spawning and fry rearing techniques and was able to
produce Jade Perch fry in mass quantity, reducing fry cost and maintaining the
supply of fry (AFCD, 2023c).
11.4.2.4
Fishponds
farms have been gradually declining in numbers since the 1970s, especially in
the Deep Bay area as these farms are being replaced by urban development. Table 11.1 presents the AFCD figures on
fishpond area and annual fish production in Hong Kong from 2013 to 2022.
Table 11.1 Fishpond Area and Annual Fish Production
in Hong Kong from 2013 to 2022
Year
|
Fishpond Area
(ha)
|
Annual Fish
Production (Tonnes)
|
2022
|
1,129
|
2,073
|
2021
|
1,130
|
2,926
|
2020
|
1,130
|
2,516
|
2019
|
1,131
|
2,278
|
2018
|
1,132
|
2,536
|
2017
|
1,132
|
2,543
|
2016
|
1,135
|
2,543
|
2015
|
1,140
|
2,092
|
2014
|
1,140
|
2,001
|
2013
|
1,150
|
2,187
|
Source: AFCD (2021, 2023a)
11.4.2.5
A
voluntary Accredited Fish Farm Scheme (AFFS) has been launched by AFCD to
assist local aquaculturists to increase the
competitiveness of their aquaculture products and to provide quality and safe
aquaculture products to the public by introducing good aquaculture practices to
local aquatic farms, increase transparency by standardising the production
process, and introducing pre-marketing product test (AFCD, 2022b).
11.4.2.6
Site
visits were conducted between 2009 and 2010 to investigate the fisheries status
of ponds under the Environmental Impact Assessment (EIA) Study for the
Development of Lok Ma Chau Loop (the Loop) (CEDD & PlanD, 2013a). No fishponds were identified within the Loop,
as they were filled and lost after the Shenzhen River Regulation Project, and the
area within the Loop was not actively managed and was considered as marshes,
dominated by emergent vegetation (prior to the development of the Loop). A mixture of active, inactive and abandoned ponds
were identified to the south of the Loop, while the
fishponds close to Ha Wan Tsuen were mainly inactive or abandoned (CEDD
& PlanD, 2013).
11.4.2.7
Under
the EIA Study conducted for the North East New
Territories New Development Areas Planning and Engineering Study –
Investigation (CEDD & PlanD, 2013b), no active fishponds were identified
within the current Assessment Area.
11.4.3
Fisheries Resources within the Assessment Area
Recent Site Visit Findings
11.4.3.1
Considering
the difference in site conditions, the Assessment Area is separated along Fanling Highway and San Tin Highway, into the northern
portion (e.g. San Tin, Sam Po Shue, Lok Ma Chau and
Chau Tau), and the southern portion (e.g. Shek Wu Wai, Ki Lun Tsuen, and Pang
Loon Tei).
11.4.3.2
During
recent site visits conducted under the current EIA Study between November 2021 and
October 2022, more than 250 fishponds were identified, mostly concentrated on
the northern portion of the Assessment Area.
The distribution and physical conditions of the ponds are similar and
comparable to the baseline conditions identified from literature review, which
are considered relevant for assessment.
Latest changes in baseline fisheries condition include some update in
the activity statuses of the fishponds, which are described below.
Summary of Fisheries Resources
11.4.3.4
Active: About 55.38 ha of active fishponds were
observed within the Project site, while the total area of active fishpond
within the Assessment Area was about 145.76 ha.
These active fishponds were observed as open water pond habitats with
active aquaculture activities and fisheries production.
11.4.3.5
Active (Indoor): Very small areas of indoor active fish
farms were observed within the Project site (about 0.03 ha), while the total of
area of indoor active fish farm within the Assessment Area was about 0.08 ha. These active indoor fish farms were mostly
located within village areas (e.g. Shek Wu Wai, Ngau Tam Mei), within enclosed
indoor structures.
11.4.3.6
Inactive: About 30.35 ha of inactive fishponds were
observed within the Project site, while the total area of inactive fishpond
within the Assessment Area was about 56.53 ha.
These inactive fishponds were observed as open water pond habitats. While no active aquaculture activities were
observed at these inactive fishponds, there are no major physical constraints
to its resumption to activities in the short-term, hence these inactive
fishponds are considered with potential values to support future aquaculture
activities.
11.4.3.7
Abandoned (Open Water): About 8.93 ha of abandoned
fishponds (open water) were observed within the Project site, with a total of
about 20.08 ha within the Assessment Area.
While these areas were observed as open water pond structure, there are no
aquaculture activities observed, with constraints in resumption of fisheries
activities, such as fenced off and inaccessible ponds, and/or overgrown pond
bunds or deteriorated pond structures.
11.4.3.8
Abandoned (Overgrown): About 4.74 ha of abandoned
fishponds (overgrown) were observed within the Project site, with a total of
about 8.91 ha within the Assessment Area.
These areas were not observed with aquaculture activities and were overgrown
with vegetation. Resumption of fisheries
activities is not anticipated at these areas.
11.4.3.9
Other Ponds (Non-Fisheries related): About 0.32 ha of other ponds
structures were observed within the Project site, with a total of about 13.32
ha within the Assessment Area. While an
open water structure was observed at these ponds, these ponds were not observed
to support any fisheries resources, with no aquaculture activities nor
fisheries production (e.g. irrigation pond, mitigation wetland, etc.). These pond structures were included in Figure 11.1 for comprehensive presentation, but does not contribute to fisheries
resources.
11.4.3.10
Assessment
on the potential fisheries impact from the loss of fishpond area and associated
fisheries resources are further described in Section 11.5.2.
Distribution of Fisheries Resources
Northern Portion
11.4.3.11
Fishponds
within the northern portion of the Assessment Area comprise some fishponds near
Lok Ma Chau and Ha Wan Tsuen, and a relatively extensive and contiguous area of
fishponds near San Tin and Sam Po Shue. Fishponds
near Lok Ma Chau and Ha Wan Tsuen comprise a mosaic of active, inactive, and abandoned
fishponds adjacent to village areas. These
fishponds were subject to some disturbances in the vicinity, including the viaduct
and the operation of LMC Spur Line, and construction activities along Ha Wan
Tsuen East Road as the western connection road for the Loop which resulted in
some portions of the ponds being completely or partially filled (Figure 11.1D refers).
11.4.3.12
Fishponds
near San Tin and Sam Po Shue area are more contiguous and larger in area. Most of these fishponds were observed with
active fisheries activities and stocked with aquaculture species. The active fishponds were mainly observed
with freshwater aquaculture species such as Common Carp, Tilapia, and
Mullets. Some inactive and abandoned
ponds were observed near the village area at Mai Po Village, which were
observed with various extent of overgrown vegetation along the pond bund and/or
within the pond area. A large area of inactive
and abandoned fishponds was observed at Sam Po Shue area, on the west of Lok Ma
Chau Boundary Control Point (LMC BCP).
This area of fishpond was observed to be fenced off, while stockpiling, heavy
vehicles, and excavators were observed within the area.
Southern Portion
11.4.3.14
All of the fishponds identified within the southern
portion of the Assessment Area were mostly small-sized and scattered between village
and agricultural areas around Shek Wu Wai, and some near Pang Loon Tei and Ngau Tam Mei.
Most of these fishponds were either active, or abandoned, showing
various signs of vegetation overgrown and transition into grassy and/or marshy
habitats. Some ponds adjacent to village
and agricultural areas were observed to be filled.
Other Observations
11.5.1
Identification of Potential Impacts
11.5.1.1
Due
to the absence of oyster culture, capture fisheries, and sites of fisheries
importance within the Assessment Area, direct and indirect impacts are not
anticipated on these resources.
Potential impacts arising from the proposed development would be loss of
pond fish culture area (i.e. fishponds), aquaculture activities and aquaculture
potential, etc. The loss of fishponds as well as other associated impacts that
would occur at construction and operation phases are as follows:
Construction Phase – Direct Impact
·
Loss of Active
Fishponds
·
Loss of Inactive
Fishponds
·
Loss of Abandoned
Fishponds
·
Temporary Loss of
Fishponds
Construction Phase – Indirect Impact
·
Deterioration of Water
Quality and Hydrological Condition
·
Indirect Injury /
Mortality on Cultured Fish
·
Bund Stability
·
Blockage of Access
Operation Phase – Indirect Impact
·
Deterioration of Water
Quality and Hydrological Condition
·
Blockage of Access
Secondary Impact from Wetland Enhancement
·
Potential Fisheries
Impact from Ecological Enhancement at Sam Po Shue Wetland Conservation Park
11.5.1.2
Each of the identified potential impacts on fisheries resources are
further described and evaluated in the following sections, with reference made
to the evaluation criteria denoted in EIAO-TM.
A summary of impacts on fisheries resources are provided in Table 11.2 – Table 11.4.
11.5.1.3
The
Government will develop the Sam Po Shue Wetland Conservation Park (SPS WCP)
with a proposed area of approximately 338 ha to create environmental capacity
for the development of San Tin Technopole.
Among
the 338 ha, while 10 ha is reserved for supporting facilities such as visitor
center and other basic infrastructure, the Government will enhance the
ecological function and capacity of
288 ha of wetlands and fisheries resources of 40 ha of fishponds by
establishing the SPS WCP with active conservation management and modernised aquaculture to compensate for the loss in
wetland habitats and fisheries resources arising from the
development of San Tin Technopole and to achieve
no-net-loss in ecological function and capacity of the wetlands concerned. The Government aims to start the
development of SPS WCP in around 2026/2027 for completion
by 2039 or earlier to tie in with the full operation of San Tin Technopole. For
the site formation works of the first batch of land at San Tin Technopole
targeted for commencement in late 2024, no pond filling will be involved. On current planning, pond filling works will
not start until 2026/27, and the pace of pond filling will tie in with the
development progress of the SPS WCP. To
this end, a working group will be formed between CEDD (as San Tin Technopole’s
works agent) and AFCD (as SPS WCP’s sponsoring department) to coordinate the
progress of pond filling and SPS WCP implementation.
11.5.2.1
Under
the Revised RODP (Figure 2.1 refers),
fishponds within the Project site will be subject to direct permanent loss as a
result of the proposed development (Figure 11.1 refers),
resulting in the direct loss of fish ponds, fisheries production, aquaculture
activities and aquaculture potential. While
some of the fishponds may potentially be preserved, subject to detailed land
use design under the Revised RODP, a conservative approach has been adopted
under the current assessment, assuming that all fishponds within the Project
boundary will be lost, except for some of the fishponds located within the proposed
AFCD Fisheries Research Centre (about 5.65 ha) where no more than 2.86 ha fishponds
will be retained, which includes about 2.00 ha of active fishpond, and 0.86 ha
of abandoned fishpond (open water) (Figure 11.3 refers). The exact area of fishponds to be retained is
subject to approval from relevant departments (AFCD) on the site requirement
during the detailed design in the subsequent design and construction stage.
Loss of Active Fishponds
11.5.2.2
Key
fisheries resources within the Project site includes active fishponds (55.38 ha)
and indoor active fish farms (0.03 ha), mostly situated near San Tin area to
the northwest of San Tin Tsuen Road, as well as some active fishponds near Ha
Wan Tsuen and in Shek Wu Wai areas. Direct
permanent loss of these active fishponds may result from the Project, except
for some of the active fishponds at the proposed AFCD Fisheries Research Centre
(refer to Figure 11.3), which would be retained under the Project (subject to AFCD’s approval
on the site requirement during detailed design and construction stage). There would be a direct permanent loss of
fisheries production and aquaculture activities at active fishponds (about 53.38
ha) and active fish farm (indoor) (0.03 ha), totalling to 53.41 ha.
11.5.2.3
The
expected loss of active fishponds and indoor fish farm (53.41 ha) makes up 53.54%
(about 53.5%) of the overall fishpond areas within the Project site (99.75 ha,
as described in Section 11.4.3.3) within the Project boundary. Some loss of aquaculture activities and
fisheries production would arise in the absence of mitigation measures, resulting
in impacts on the local fisheries industry. Considering
the potential cumulative impact (combined loss of active fishponds with
concurrent projects) as described in Section 11.6, mitigation measures (such as the compensation
of fishpond areas and development of modernised aquaculture practices) are
proposed in Section 11.7.
Loss of Inactive Fishponds
11.5.2.5
Under
a conservative approach adopted under the current assessment, potential minor
impact may arise due to the potential of these inactive ponds. While fisheries production is not anticipated
from these inactive fishponds, mitigation measures (compensation of fishpond
areas) are also considered, due to the potential value of these inactive
fishponds to be reverted to support aquaculture in the future, and the
cumulative impact as described in Section 11.6.
Mitigation measures are further described in Section 11.7.
Loss of Abandoned
Fishponds
11.5.2.6
Abandoned
fishponds (open water) (8.93 ha) and abandoned fishponds (overgrown) (4.74 ha) were
identified within the Project site. No
fisheries activities were identified at these abandoned fishponds, while the
conditions of these fishponds were no longer suitable for short-term resumption
into active fisheries activities (e.g. inaccessibility, deteriorated pond bund
and overall pond structure, habitat transition, etc.). Furthermore, 0.86 ha of abandoned fishponds
(open water) would be retained at the proposed AFCD Fisheries Research Centre
under the Project (Section 11.5.2.1 refers), subject to AFCD’s approval on the
site requirement during detailed design and construction stage. Direct loss of these abandoned fishponds
(open water) (8.07 ha) and abandoned fishponds (overgrown) (about 4.74 ha). The loss of these abandoned fishpond areas is
not likely to result in significant impact on aquaculture activities.
Temporary Loss of
Fishponds
11.5.2.7
Under
the current Project layout, some ponds will be partially encroached by the
Project boundary. During the
construction phase, all ponds and wet areas to be
removed shall be isolated and not connected to any existing watercourse. The associated construction works would
include draining the water in ponds before filling up these areas or before
commencement of any excavation and construction works. As such, some temporary loss of ponds
adjacent to the Project boundary may also arise during the construction
phase. Considering the short-term and
reversible nature of these temporary loss, fisheries impact is anticipated to
be minor.
11.5.3
Construction Phase – Indirect Impact
Deterioration of
Water Quality and Hydrological Condition
11.5.3.1
Some
active fishponds were situated directly adjacent to the Project boundary,
including some fishponds at San Tin area (adjacent to the northwest boundary),
and some small and scattered at LMC (adjacent to the northeast boundary). Considering the proximity and the downstream
location of these active fishponds to the development boundary, indirect
impacts on cultured fish may arise from construction activities (e.g. deterioration
of water quality from uncontrolled run-off and erosion of exposed bare soil and
earth, increase in suspended solids, excavated materials and sediments from
construction works in ponds, potential chemical and contaminant spillage,
potential change in hydrodynamics, and blockage of access roads).
11.5.3.2
In
the absence of mitigation measures, this could result in potentially minor to
moderate impacts on the remaining ponds, particularly those that were located
adjacent to the Project boundary. Examples
of relevant water quality control measures are provided in Section 11.7.1, while details of these mitigation measures
are available at Section 5.
With the proper implementation of these mitigation measures,
unacceptable impacts on water quality are not expected. There will be no adverse impacts on cultured
fish due to potential water quality deterioration during the construction
phase.
11.5.3.3
As the fishponds within the Assessment Area mostly rely on rainwater and
adjacent fishponds as water sources, potential water quality impacts on the
nearby watercourses are also not likely to result in indirect impacts on the cultured
fish.
Indirect Injury / Mortality of Cultured Fish
11.5.3.4
Indirect
water quality impact from construction activities may affect the survival of cultured
fish. For example, accidental spills of
oils and other chemicals could affect aquatic organisms (including aquaculture
fisheries), resulting in lethal / sublethal impacts (e.g. direct mortality,
reproductive retardation). Removal of
vegetation during site formation could also elevate sediment levels in site
runoff, increasing suspended solids (SS) level in the aquatic environment. Furthermore, discharge from land-based
construction works (e.g. excavated materials and sediments from construction works
in ponds, general cleaning and polishing, wheel washing, dust suppression,
utility installation, etc.) and construction site runoff (e.g. runoff and
erosion of exposed bare soil and earth, earth working area and stockpiles,
etc.) could also cause a temporary increase in SS level. Such increase in suspended particles could
potentially injure cultured fish and clog their respiratory and feeding systems,
resulting in impact on fisheries production.
11.5.3.5
Mitigation
measures will be implemented to control runoff and drainage from the
construction site, as well as the adoption of guidelines and good site
practices for handling and disposal of construction discharges, excavated
materials and sediments (refer to Section 5 and 11.7.1). Unacceptable
impacts on water quality, and the associated potential indirect injury /
mortality on cultured fish are not expected.
Bund Stability
11.5.3.6
Construction
activities that occur adjacent or in close vicinity to fishponds may result in
indirect impacts on these fishponds by affecting the stability of the pond
bund, potentially resulting in instability of the pond structure, or water
seepage. In the absence of mitigation
measures, this could inhibit pond usage and result in potentially minor to
moderate impacts on the remaining ponds adjacent to the development
boundary. With appropriate mitigation
measures implemented to ensure the stability of the pond bund during
construction phase, (e.g. sheet pile wall and associated grouting, further
described in Section 11.7.1.1), adverse impacts on aquaculture activities
are not anticipated.
Blockage of
Access
11.5.3.7
During
construction phase, construction activities and associated temporary works
(e.g. stockpiling area) may potentially affect the access to the remaining
fishpond areas. Without mitigation
measures, this may result in minor to moderate impact on fishpond area. Mitigation measures (e.g. provision of
temporary road and access arrangement) would be in place to minimise the
potential blockage and the associated impact on fishpond area. The construction within the Project boundary
has also been separated into various phases, allowing provision of access to
the fishpond areas.
11.5.4
Operation Phase – Direct Impact
11.5.4.1
In
view of the land use under the Revised RODP, no additional direct impacts on
fisheries resources (e.g. loss of fishponds) are anticipated during the operation
phase of the proposed development.
11.5.5
Operation Phase – Indirect Impact
Deterioration of Water Quality
11.5.5.1
As
described above, some active fishponds were situated directly adjacent to the Project
boundary, at San Tin and LMC areas.
Potential indirect impacts could arise from uncontrolled surface runoff,
and subsequent deterioration in water quality.
Mitigation measures will be implemented for potential water quality
impact arising from the operation phase of the Project (refer to Section 5).
Furthermore, in view of the proposed land use under the Revised RODP, an
“eco-interface” with widths of 20 – 35 m was proposed along the northwest of
the Project boundary near San Tin area.
This “eco-interface” area would comprise eco-friendly and/or landscaping
features to provide buffer to the remaining fishponds and other wetland
habitats near San Tin area. Sewage
discharge and/or surface runoff are not anticipated from this “eco-interface”
area. Adverse impacts on cultured fish
due to potential water quality deterioration during the operation phase are not
anticipated.
Blockage of Access
11.5.5.2
Considering
the provision of access during construction phase, and upon the completion of
construction activities, no further impact is anticipated to arise during the
operation phase of the proposed development.
Potential
Fisheries Impact from Ecological Enhancement at the proposed SPS WCP
11.5.6.1
Under
the ecological impact assessment of this study (Section 10 refers), enhancements in the form
of “ecologically enhanced fishponds” and “enhanced freshwater wetland habitat” are
proposed as mitigation measure for the unavoidable loss of ponds and other
freshwater wetland habitats under the Revised RODP as well as to achieve
no-net-loss in ecological function and capacity of the wetlands concerned. The enhanced wetland would be implemented
within the proposed SPS WCP, located on the northwest of the Project boundary (Figure 11.2 refers). Details on the wetland compensation framework
(including enhanced wetland) are provided in Section 10 (Ecological Impact Assessment) and
subject to further planning and design under later studies of the proposed SPS
WCP project.
11.5.6.2
Upon
the establishment of the proposed SPS WCP, the WCP is expected to enhance the
ecological function and capacity of 288 ha of wetlands (253 ha of “ecologically
enhanced fishponds” and 35 ha of “enhanced freshwater wetland habitats”). Fishponds
within the San Tin and Sam Po Shue area mostly comprise active fishponds, while
small areas of inactive fishponds, abandoned fishponds, and brownfields were
also observed.
11.5.6.4
On
the other hand, the proposed wetland enhancement will also involve the
conversion of some inactive fishponds, abandoned fishponds, and brownfields
into “ecologically enhanced fishponds”.
No existing aquaculture production is anticipated at these inactive
fishponds, abandoned fishponds, and brownfields, while some aquaculture production
is anticipated upon the establishment of ecologically enhanced fishponds. As such, a coordinated management of fishponds under the proposed SPS WCP would
be adopted, and no significant impact on the overall aquaculture activities and
production would be anticipated.
11.5.7
Summary of Fisheries Impact
11.5.7.1
Based
on the above discussion, potential adverse impacts on fisheries resources
arising from the construction, operation, and associated wetland enhancement of
the Project, where present, are summarised in Table 11.2 – Table 11.4.
Table 11.2 Summary of Impact on Fisheries Resources (Active
Fishponds)
Criteria
|
Proposed Development
|
Wetland Enhancement
at the proposed SPS WCP
|
Construction Phase
|
Operation Phase
|
Nature of impact
|
Direct impact:
-
Permanent loss of active
fishponds
-
Temporary loss due to pond
draining along Project boundary (minor)
Indirect impact:
-
None anticipated with
mitigation measures
|
No adverse direct and indirect impacts are
anticipated
|
Direct and indirect impact:
-
None anticipated
Secondary impact:
-
Fisheries production anticipated
to slightly decrease at existing active fishponds
|
Size of affected area
|
Direct impact:
-
Permanent loss of active
fishpond: 53.38 ha
-
Permanent loss of active fish
farm (indoor): 0.03 ha
Indirect impact:
-
Minor to moderate in the
absence of mitigation measures
|
N/A
|
Direct and indirect impact:
-
None anticipated
Secondary Impact:
-
Subject to detailed design
of enhanced wetland (288 ha) within SPS WCP
|
Loss of fisheries resources
|
Direct loss of aquaculture activities and fisheries
production
|
N/A
|
Fisheries production anticipated to slightly
decrease due to ecological management
|
Destruction and disturbance of nursery and
spawning grounds
|
N/A
(No nursery and spawning ground within
Assessment Area)
|
Impacts on fishing activity
|
N/A
(No fishing activities within Assessment
Area)
|
Impact on aquaculture activity
|
Loss of aquaculture activity from loss of
active fishponds
|
N/A
|
Potential reduction of fisheries resources
|
Overall
impact before mitigation
|
Moderate
|
Insignificant
|
Minor
|
Table 11.3 Summary of Impact on Fisheries Resources
(Inactive Fishponds)
Criteria
|
Proposed Development
|
Wetland Enhancement
at the proposed SPS WCP
|
Construction Phase
|
Operation Phase
|
Nature of impact
|
Direct impact:
-
Permanent loss of inactive
fishponds (which would also result in loss in aquaculture potential)
-
Temporary loss due to pond
draining along Project boundary
Indirect impact:
-
None anticipated
|
No adverse direct and indirect impacts are
anticipated
|
Direct impact:
-
Some inactive fishponds in
SPS WCP will be converted to ecologically enhanced fishponds
Indirect impact:
-
None anticipated
Secondary impact:
-
Increase in fisheries
production
|
Size of affected area
|
Direct impact:
-
Permanent loss of inactive
fishpond: 30.35 ha
Indirect impact:
-
None anticipated
|
N/A
|
-
Subject to detailed design
of the enhanced wetland (288 ha)
|
Loss of fisheries resources
|
Considering no active aquaculture observed,
no loss of fisheries production anticipated
|
N/A
|
None – fisheries production is expected to
increase
|
Destruction and disturbance of nursery and
spawning grounds
|
N/A
(No nursery and spawning ground within
Assessment Area)
|
Impacts on fishing activity
|
N/A
(No fishing activities within Assessment
Area)
|
Impact on aquaculture activity
|
None anticipated
|
N/A
|
Increased area for aquaculture activity upon fishpond conversion
|
Overall
impact before mitigation
|
Minor
|
Insignificant
|
Insignificant
|
Table
11.4 Summary of Impact on Fisheries Resources
(Abandoned Fishponds)
Criteria
|
Proposed Development
|
Wetland Enhancement
at the proposed SPS WCP
|
Construction Phase
|
Operation Phase
|
Nature of impact
|
Direct impact:
-
Permanent loss of
abandoned fishponds
-
Temporary loss due to pond
draining along Project boundary
Indirect impact:
-
None anticipated
|
No adverse direct and
indirect impacts are anticipated
|
Direct impact:
-
Some abandoned fishponds
in SPS WCP will be converted to ecologically enhanced fishponds
Indirect impact:
-
None anticipated
Secondary impact:
-
Increase in fisheries
production
|
Size of affected area
|
Direct impact:
-
Permanent loss of
abandoned fishpond (open water): 8.07 ha
-
Permanent loss of
abandoned fishpond (overgrown): 4.74 ha
Indirect impact:
-
None anticipated
|
N/A
|
-
Subject to detailed design
of the enhanced wetland (288 ha)
|
Loss of fisheries
resources
|
Considering no active
aquaculture observed, no loss of fisheries production anticipated
|
N/A
|
None – fisheries production
is expected to increase
|
Destruction and
disturbance of nursery and spawning grounds
|
N/A
(No nursery and spawning
ground within Assessment Area)
|
Impacts on fishing
activity
|
N/A
(No fishing activities
within Assessment Area)
|
Impact on aquaculture
activity
|
None anticipated
|
N/A
|
Increased area for aquaculture activity upon
fishpond conversion
|
Overall impact before mitigation
|
Insignificant
|
Insignificant
|
Insignificant
|
11.6.1.1
Cumulative impact may arise
during the construction and operation of the proposed Project, due to interaction with other
developments in the area. Major
concurrent projects that may impose cumulative impact on aquaculture activities
and production include the Development of LMC Loop – Main Works Package 1, and
the Strategic Feasibility Study on the Development of Wetland Conservation
Parks (WCP) System under the Northern Metropolis Development Strategy (Table 2.7 of
Section 2 refers).
11.6.1.2
Under the development of the
Loop, the loss of fisheries resources was assessed to be minor impact (CEDD
& PlanD, 2013a). Nonetheless, with the
direct loss of active and inactive fishponds from the proposed development
under the current assignment, aquaculture production in the wider San Tin
and LMC area may be subject to potential cumulative loss.
11.6.1.3
Mitigation measures are
proposed under the current Project to minimise the potential impact on aquaculture activities, which includes compensation and enhancement
measures, further detailed in Section 11.7. With the
implementation of the mitigation measures, fisheries impact arising from the
current Project are expected to be mitigated to an acceptable level. No adverse cumulative impact on aquaculture activities is expected with the implementation of mitigation
measures.
Maintaining Bund
Stability
Minimisation of Potential Water Quality Impacts
11.7.1.2
As
described in Section 11.5, impact on cultured fish due to the
potential deterioration of water quality are not anticipated. Mitigation measures and good site practices
should be implemented during the construction phase, as proposed in Section 5 (e.g. proper covering of
construction debris and stockpiling of material to avoid runoff into the
ponds), to further minimise potential water quality impact on the ponds
adjacent to the Project boundary.
Surface drainage system shall also be provided to collect road run-off
during the operation phase of the Project.
Examples of mitigation measures for potential water quality impact
include:
Control of Site Run-off
·
Implementation of Best
Management Practices (BMPs), following the guidelines for handling and disposal
of construction site discharges detailed in ProPECC
PN 1/94 "Construction Site Drainage";
·
Controlling surface
run-off from construction site into storm drains via adequately designed
channels, earth bunds or sand bag barriers, directing
the runoff to sand / silt removal facilities such as sand traps, silt traps and
sedimentation basins;
·
Minimising soil
excavation in wet season (April to September), or where impracticable, proper
covering of temporarily exposed slope surfaces, while intercepting channels
should be provided along the crest / edge of excavation;
·
Proper covering of open
stockpiles of construction materials during rainstorms (e.g. with tarpaulin or
similar fabric).
Control of Other
Construction-Related Activities
·
All vehicles and plants
should be cleaned before they leave the construction site to minimise the
deposition of earth, mud and debris in surrounding areas;
·
Acidic wastewater
generated from acid cleaning, etching, pickling and similar activities should
be neutralised to within the pH range of 6 to 10 before discharging into foul
sewers. If there is no public foul sewer
in the vicinity, the neutralized wastewater should be tankered
off site for disposal into foul sewers or treated to a standard acceptable to
storm drains and the receiving waters;
·
The Waste Disposal
Ordinance (Cap 354) and its subsidiary regulations in
particular the Waste Disposal (Chemical Waste) (General) Regulation,
should be observed and complied with for control of chemical wastes. The Contractor is also recommended to develop
management procedures for chemicals used and prepare an emergency spillage
handling procedure to deal with chemical spillage in case of accidents.
11.7.1.3
Further
details of these mitigation measures are available at Section 5. With the implementation of the above mitigation
measures and the mitigation measures as described under the Water Quality Impact Assessment (refer to Section 5), no adverse impact on cultured
fish is anticipated from the Project.
Direct Loss of Aquaculture
Activities
11.7.2.1
Under
the Project, there will be unavoidable loss of fishponds, mainly at San Tin and
LMC areas, and a small area of fishponds near Shek Wu Wai area. As discussed in Section 11.5 and Table 11.2 – Table 11.4, moderate and minor impacts on aquaculture
activities are anticipated from the direct loss of active fishponds (about 53 ha)
and inactive fishponds (about 30 ha) respectively, under the Project. Considering the concurrent projects and the
potential cumulative impact on aquaculture activities in the wider San Tin and LMC
area, the loss of active and inactive fishponds (about 83 ha) will be
compensated within the proposed SPS WCP (Figure 11.2 refers). The Government aims to start the
development of SPS WCP in around 2026/2027 for completion by 2039
or earlier to tie in with the full operation of San Tin Technopole. For the site formation works of the first
batch of land at San Tin Technopole targeted for commencement in late 2024, no
pond filling will be involved. On
current planning, pond filling works will not start until 2026/27, and the pace
of pond filling will tie in with the development progress of the SPS WCP. To this end, a working group will be formed
between CEDD (as San Tin Technopole’s works agent) and AFCD (as SPS WCP’s
sponsoring department) to coordinate the progress of pond filling and SPS WCP
implementation.
Secondary Impact from Wetland Enhancement at the
proposed SPS WCP
11.7.2.2
As
discussed in Section 11.5.6, existing fishponds within the proposed
SPS WCP would be subject to active conservation management measures under the
wetland compensation framework (through enhancement of ecological functional
value) to compensate for the loss in wetland habitats arising from the
development of San Tin Technopole, resulting in some potential decrease in aquaculture
production and minor impact on aquaculture activities. Nonetheless, these “ecologically enhanced
fishponds” are anticipated to continuously support aquaculture activities and
pond fish culture, thus serving dual functions alongside wetland
enhancement. On the other hand, upon the
establishment of the proposed SPS WCP, aquaculture production would also be
increased from the conversion of existing inactive and abandoned fishponds, as
well as brownfield areas into “ecologically enhanced fishponds”. As these ponds will be under coordinated
management in the proposed SPS WCP, no further compensation area would be
required.
Fisheries
Compensation
11.7.2.3
The
requirement of fisheries compensation mainly arises from the direct permanent loss
of active fishponds (which support existing aquaculture activities and
production), and the permanent loss of inactive fishponds (with potential value
to support future aquaculture activities upon conversion). The Government will introduce a suite of
mitigation measures to enhance the fisheries resources (e.g.
fisheries activities and production, culture area and aquaculture potential
etc.) of the proposed SPS WCP with a view to compensate for the loss of
fishponds arising from the development of the San Tin Technopole as well as
making an overall improvement to the utilisation of fisheries resources for
aquaculture and promoting sustainable development of the industry in the long
run. The Government will enhance the fisheries resources of 40 ha of land in
the SPS WCP, including incorporation of modernised aquaculture, to compensate
for the loss in fisheries resources
arising from the development of San Tin Technopole. Descriptions and justifications of these mitigation measures are described in
Sections 11.7.2.4 to 11.7.2.16.
Fisheries Enhancement
Area in the proposed SPS WCP
11.7.2.4
The
Government will reserve 40 ha of land in the proposed SPS WCP as a fisheries
enhancement area, in which the fisheries resources will be enhanced by incorporation of modernised aquaculture
and proper planning and management of aquaculture activities therein. The fisheries enhancement area
shall be delineated separately from the 253 ha “ecologically enhanced
fishponds”, of which the purpose would conflict with aquaculture activities for
food fish production since the “ecologically enhanced fishponds” mainly serve
to provide ecological enhancement and attract foraging birds and other
wildlife.
11.7.2.5
The
proposed fisheries enhancement area shall utilise existing fishponds, abandoned
fishponds, and brownfield areas within the proposed SPS WCP as far as possible,
and shall be actively managed for modernised aquaculture, comprising both
indoor and outdoor facilities, where aquaculture activities and fisheries
production are generally anticipated to be multiplied upon establishment.
The aforementioned
measures would improve both the yield and the quality of aquaculture
production, promoting the sustainable development and modernization of the
fisheries industry.
11.7.2.6
Modernised
aquaculture generally refers to intensive high-density aquaculture activities,
indoor or outdoor, with the adoption of innovative green technologies, such as
recirculating aquaculture system (RAS), compartmentalisation, remote real-time
environmental monitoring, species selection, ecological polyculture, nutrition
management, disease prevention and health management, etc., that create water
bodies and environmental conditions suitable for fish growth under high-density
stocking conditions.
11.7.2.7
Compared
to traditional pond fish farming practices, the introduction of modernised
aquaculture technology and management would enable fisheries operation in a
compact area while achieving a higher level of aquaculture production. For example, RAS in China has achieved more
than double aquaculture production (Li and Zhang, 2011); while the Grass Carp
individuals produced with RAS were reported to be of better sizes and quality,
thus more popular with consumers (Zhou et al., 2019). Other example of modernised aquaculture in
China was reported to involve constructed aquaculture tanks of 3 m tall, 12 m
wide, and was reported to result in 15-fold fisheries production in Jiangmen (XinHui, 2023). Another
example in Shaoguan has also report production of Sweetfish with improved quality and market price (Hong Kong
Commercial Daily, 2023). Overseas
examples of RAS have also suggested better control over environmental
parameters, and reduced water consumption (EUMOFA, 2020). Compartmentalisation in aquaculture
production systems has been suggested to provide better control and management
of aquaculture disease emergencies (Zepeda et al., 2008). These applications would improve both the
yield and the quality of aquaculture production, providing an overall improvement
in the aquaculture industry.
11.7.2.8
Specifically,
the application of RAS has been suggested as the way-forward in the future of
aquaculture (Wu et al., 2017). In light of the increased requirement to effectively
regulate water quality to ensure sustainable development of aquaculture, RAS
has gained momentum and increased in its application. With the application of RAS, stocking density
was highly increased with enhanced overall production, such as a maximum yield
of 100 kg/m3 in Europe, and in some cases, up to 300 kg/m3 (pikeperch
production in the Netherlands). In
France, almost all fingerling production and rearing of turbot and sole
are carried out using RAS, while about 70% of aquaculture production is
achieved through RAS in Spain and Portugal.
Rearing of salmon fry has increased via the application of RAS in
Norway, from 350,000 individuals in 2005 to 3.8 million individuals in 2009,
suggesting 11-fold increase. Aside from
increase production, increased aquaculture diversity was observed, where RAS
has started its application to various aquaculture species, now encompassing
shrimp, shellfish, and algae farming.
In North America, RAS models are highly developed for culturing
cold-water species such as salmon and trout.
RAS is the development direction for land-based aquaculture in mainland
China, and it can only be achieved through large-scale and high-efficiency
farming. In 2014, the scale of
industrial aquaculture in China approached nearly 60 million m2,
with a production of 367,000 tonnes. Among them, the scale of industrial marine
aquaculture accounted for over 25.645 million m2, with a production
of 170,000 tonnes. The combined marine industrial aquaculture areas
of Shandong and Fujian provinces accounted for more than half of the national
total. The marine industrial aquaculture
areas in Tianjin and Hainan provinces are quite similar, both exceeding 400,000
m2 (Wu et al.,
2017).
11.7.2.9
Modernisation
of aquaculture practices was well-received from interview and discussion with
the local fish farmers (Section 11.4.3.13 refers). With the incorporation of modernised
aquaculture, and with multiplied fisheries production anticipated, the
enhancement of fisheries resources at the proposed fisheries enhancement area would be adequate to
compensate for the loss of active and inactive fishponds. No unacceptable impact on fisheries resource would
be anticipated upon the implementation of fisheries enhancement area. Detailed design of the fisheries enhancement area
would be further formulated in later detailed studies of the proposed SPS WCP
project.
Establishing the
AFCD Fisheries Research Centre
11.7.2.10
While
modernised aquaculture (such as compartmentalisation) has been practised in
Hong Kong in some extent (SkyPost, 2019), these
aquaculture activities have not been well-documented and lacks technical
support, hence are yet to be widespread and well-established within the
industry. Proper technical support would ensure the proper implementation of
these practices to enhance actual fisheries aquaculture production. As such, under
the Project, an AFCD Fisheries Research Centre shall be established at a
location near the Loop (Figure 11.3 refers) to bridge the technical gap by providing support to the
modernised aquaculture that is currently practised only in a limit extent in
Hong Kong. Details of layout and design
are subject to AFCD’s approval on the site requirement in the design and
construction stage.
11.7.2.11
The
proposed AFCD Fisheries Research Centre shall be implemented with accorded
priority under the initial phase of the Project, for it is indispensable in
serving a vital role in the provision of mitigation measures by promoting
modernised aquaculture, conducting aquaculture research, and transferring
modernised aquaculture techniques to local fish farms, thus facilitating the
transformation and upgrading of the industry through technological advancement
and improving aquaculture activities in the area.
11.7.2.12
Furthermore,
the proposed AFCD Fisheries Research Centre would be implemented under the
initial phase of the Project, while the majority of the fishpond loss in San
Tin and Sam Po Shue would occur during the main phase of the Project (refer to Appendix 2.1 for development phasing plan). With the early establishment of the Fisheries
Research Centre, early enhancement of aquaculture production and activities
would be possible, thus minimising fisheries impact before the establishment of
fisheries enhancement area in the proposed SPS WCP.
Proper Planning of Aquaculture Activities in the
proposed SPS WCP
11.7.2.13
In order to enhance efficiency of the overall aquaculture
activities and fisheries production, a compensation strategy shall be implemented
at the fisheries enhancement areas, and at the overall fishponds within the
proposed SPS WCP. The compensation
strategy shall include proper replanning of fishpond areas and wetland habitats
within the SPS WCP, incorporating suitable modernised aquaculture technology
and management practice in accordance with the environmental constraints and
the purpose of aquaculture operation, and centralising the same types of aquaculture
activities in the same area, etc. Details
of the compensation strategy would be further formulated in later detailed
studies of the proposed SPS WCP project.
Other Benefits from Fisheries Enhancement Area with
Modernised Aquaculture
11.7.2.14
In addition to achieving a higher level of
aquaculture production with less space, modernised aquaculture can achieve
other value-added effects to the aquaculture industry and the environment such
as time and energy saving, reduction in aquaculture sewage and carbon emissions,
and income improvement. For example, RAS
would achieve an ecological aquaculture system with zero wastewater discharge,
and advantageous to the protection of surrounding water bodies (Peng et al.,
2010; EUMOFA, 2020);
while compartmentalised aquaculture production systems would exert better
environmental control and minimise outbreak of disease (Zepeda et al., 2008). These factors (improved culture environment
and minimisation of disease) would result in a better yield and income due to
improved quality and potential market price of the aquaculture production. Other value-added effect such as time and
energy saving would also suggest reduced cost of the aquaculture activities,
but improved yield and income. As such,
the implementation of modernised aquaculture would not only increase the aquaculture
production, but would also improve the environmental
sustainability and social economy of aquaculture activities, subsequently
contributing to the sustainable development of the industry in the long run.
11.7.2.15
All of the
above measures would also compensate for the loss of aquaculture opportunities
and fisheries production due to the concurrent development projects; as well as
provide affected fish farmers with land for rehabilitation of fish farming
business and create a positive synergistic effect on conservation of wetland
and aquaculture activities.
11.8.1.1
As described under Section 11.5 and 11.6, in the absence of mitigation measures, minor and
moderate impacts may arise from the loss of aquaculture production and activities
from the construction phase of the Project. Combined with the cumulative impact arising
from concurrent projects in the vicinity, residual impact may arise in the
absence of mitigation measures.
11.8.1.2
As discussed in Section 11.7, compensation measures have been recommended under
the EIA Study, including proposed fisheries enhancement area (40 ha) within the
proposed SPS WCP with enhanced fisheries resources, implementation of
modernised aquaculture, the establishment of indoor aquaculture facilities, and
associated mitigation measures to improve aquaculture
activities and fisheries production, with the proposed AFCD Fisheries Research
Centre within the Project to bring forth technological advancement in the area. Upon the implementation of the proposed
mitigation measures, no residual impact is anticipated from the Project.
11.8.1.3
Some loss of aquaculture production
and activities are still observed during the time gap from the commencement of
Project and the establishment of SPS WCP.
11.9.1.1
With the implementation of
mitigation and precautionary measures proposed in Section 5, potential water quality
impacts arising from the Project would be minimised. No specific EM&A programme is required
for the potential water quality impact in association with fisheries impact
because the monitoring and audit requirement have been covered by the EM&A
programme for potential water quality impact recommended in Section 5. The loss of fishpond (i.e. loss of aquaculture area), aquaculture
activities and potential will also be
compensated by the
40 ha of area within the SPS WCP reserved solely for aquaculture, through measures described in Section 11.7.2 (including incorporation of modernised aquaculture and
the development of Fisheries Research Centre, etc.), while the location and
detailed design would be subject to subsequent study. The implementation details of the fisheries
enhancement area, the associated management, the supervision, and the
maintenance works at the operation stage would be included during the detailed
design. As the overall enhancement of
fisheries resources brought about by the mitigation measures is
qualitative in nature and non-measurable, no further specific monitoring and
audit programme for fisheries resources and aquaculture activities would be
necessary.
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