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Complaint Management Plan for Tung Chung New Town Extension (East) (EP No. EP-519/2016)
December 2022
Revision Number | Date | Amendment |
1 | July 2018 | - First submission |
2 | March 2022 |
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3 | September 2022 |
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4 | December 2022 |
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Table of Contents
Scope of Works for Tung Chung East (TCE) 2
Tung Chung New Town Extension – Reclamation and Advance Works (Contract No. NL/2017/03) (C1) 2
Tung Chung New Town Extension – Salt Water Supply System (Contract No. NL/2020/02) (C2) 2
Tung Chung New Town Extension – Major Infrastructure Works in Tung Chung East (Contract No. NL/2020/03) (C3) 3
Tung Chung New Town Extension – Tai Ho Interchange (Contract No. NL/2020/07) (C7) 3
Dedicated Complaint Hotline and Email Channel for the Project
Complaint Management Process for TCE
Appendix A – Environmental Complaint Handling Flow Chart
Appendix C – Plan showing the Site Boundaries of Contracts in TCE
The Environmental Impact Assessment (EIA) Report (Register No.: AEIAR-196/2016) prepared for the “Tung Chung New Town Extension” (hereinafter referred to as “the Project”) has been approved by the Director of Environmental Protection, and an Environmental Permit (EP) (Permit No.: EP-519/2016) has been issued for the Project under the Environmental Impact Assessment Ordinance. This submission of Complaint Management Plan (CMP) has been prepared in accordance with Condition 2.1 of the EP to include a dedicated complaint hotline and an email channel for timely response to complaints. The complaint handling procedure will be discussed in detail in following sessions to ensure timely investigation and response to environmental complaints.
The development of Tung Chung New Town Extension (TCNTE), comprising Tung Chung East (TCE) and Tung Chung West (TCW), is a mega-scale and complex project aiming to provide land to meet the future housing economic and social development needs of Hong Kong. Due to the fact that the proposed works are geographically separated, the implementation of mega-scale project is divided into two packages, namely TCE and TCW respectively. In accordance with the tight delivery programme, the Project will be implemented in phases under separate contracts for the developments of TCE and TCW. This submission only covers the CMP for TCE. The CMP for TCW can be found at the dedicated project website: https://www.env.tcnte-west.hk/en/ep-submissions.html.
Scope of Works for Tung Chung East (TCE)
Plans showing the boundaries of the four contracts in TCE for information are enclosed in Appendix C.
Tung Chung New Town Extension – Reclamation and Advance Works (Contract No. NL/2017/03) (C1)
Build King – SCT Joint Venture (BKSCTJV) is the Contractor appointed to undertake the reclamation works in Tung Chung East and the advance works for the Project. The works mainly comprise:-
Reclamation of the seabed by a non-dredged method at Tung Chung East (TCE) to form a total of about 130 hectares of land;
Construction of about 4.9 kilometers of seawalls with eco-shoreline, three drainage box culvert outfalls, three circulation drains and a seawater intake;
Construction of about a 470-metre long multi-cell drainage box culvert at TCE;
Provision of infrastructure for Tung Chung Area 58, including construction of a single two-lane road with a footpath of about 270 meters in length and the associated utility works; and
Associated environmental mitigation measures.
Tung Chung New Town Extension – Salt Water Supply System (Contract No. NL/2020/02) (C2)
China Geo-engineering Corporation (CGC) is the Contractor appointed to undertake the construction of salt water supply system for the Project. The works mainly comprise:-
Construction of Tung Chung Salt Water Pumping Station at Tung Chung East reclamation area with a pumping capacity of 54,000 m3 per day;
Construction of Tung Chung Salt Water Service Reservoir near Chek Lap Lok New Village with a storage capacity of about 11,500 m3;
Laying of about 2,600m long salt watermains;
Laying of about 1,500m long fresh watermains;
Compensatory woodland planting near Tung Chung Salt Water Service Reservoir; and
Associated civil, geotechnical, structural, building services systems, electrical and mechanical engineering and landscape works.
Build King Civil Engineering Limited (BKCEL) is the Contractor appointed to undertake the construction of main infrastructure works for the Project. The works mainly comprise:-
Construction of engineering infrastructure including drainage works, sewerage works (including two sewage pumping stations), waterworks, roadworks (including carriageways, footpaths, cycle tracks and junction improvements), common utility tunnels and landscaping works; and
Construction of associated environmental mitigation works including noise barriers and low-noise road surfacing.
Tung Chung New Town Extension – Tai Ho Interchange (Contract No. NL/2020/07) (C7)
Build King Civil Engineering Limited (BKCEL) is the Contractor appointed to undertake the construction of Tai Ho Interchange connecting North Lantau Highway, Road P1 and Cheung Tung Road, construction of a section of dual two-lane Road P1 between Tung Chung East and Tai Ho Interchange, laying of fresh water, salt water and sewage rising mains, associated civil, geotechnical and landscaping works for the Project. The works mainly comprise:-
Construction of around 4km of roads, drainage, sewerage, watermains and utilities respectively;
Construction of Pak Mong Subway Extension and Modification to Existing Pak Mong Subway;
Construction of Bridge C connecting Roundabout P1 to Tai Ho Interchange;
Modification works to Tai Ho Box Structure;
Construction of North Lantau Highway overbridge Bridge A1 and A2;
Construction of sliproads SR-A1, SR-A2, SR-A4 and SR-A5 to North Lantau Highway;
Construction of sliproads SR-A3 to Cheung Tung Road; and
Construction of Retaining Structures and Earthworks.
The CMP is prepared in accordance with Condition 2.1 of the EP to detail the complaint handling procedure on environmental complaints for TCE to ensure the complaints are timely investigated and responded. The CMP includes a dedicated complaint hotline and an email channel for timely response to complaints. The handling procedure of non-environmental-related complaints is not covered in this CMP.
The key parties involved in the CMP and their overall roles and responsibilities are presented in Table 1.1.
Table 1.1 Key Parties Involved in the CMP
Party | Roles and Responsibilities |
CEDD | The CEDD, as the Project proponent, bears the overall responsibility for the Project, and has to assure that the CMP is issued and followed by all the relevant parties of the Project. |
Project Manager (PM) | AECOM Asia Co. Ltd. (AACL) is commissioned by CEDD as the PM for TCE. The PM is responsible for ensuring the Contractor(s) has followed the CMP and implemented their proposed remedial measures to address environmental complaints. |
Environmental Team (ET) | The ET is responsible for consulting and reviewing the proposed remedial measures, carrying out additional monitoring and audit, and recording the findings as part of the EM&A process. |
Independent Environmental Checker (IEC) | The IEC is responsible for auditing the complaints handling, investigation, reporting process and the effectiveness of mitigation measures implemented by the Contractor(s). |
Contractor(s) of individual contracts | The Contractor(s) has the primary responsibility for implementing the required mitigation measures and ensuring their works comply with all environmental legislation and the EP requirements as well as any additional conditions specified in their works contracts. The Contractor(s) is responsible for providing all necessary input / information to the ET as part of the complaint investigation process. The Contractor(s) is also required to implement all mitigation measures, corrective actions or any additional measures required to address environmental complaints. |
Dedicated Hotline Number: 5976 1853 Dedicated Email Channel: enquiry@tungchungnte.com
As part of the EM&A requirements of the Project, the TCE environmental complaint handling process is shown in Figure 3.1. Details of each of the stages in the handling process are described in the following sections. A detailed environmental complaint handling flow chart for TCE is shown in Appendix A.
Figure 3.1 Overall Environmental Complaint Handling Process Flow Chart for TCE
Stage 1 – Receiving the Complaint
Complaint Received from the Dedicated Project Hotline and Email
The public can raise environmental complaints that are related to the Project via telephone through the dedicated hotline or via email through the dedicated email mentioned in Section 2. Every complaint/enquiry case received by the hotline will be recorded and forwarded by the third-party hotline service operator to the list of responsible personnel of each TCE contract through SMS, tabulated in Table 3.1. For complaint/enquiry case received via email, the email will be automatically forwarded to the list of responsible personnel of each TCE contract tabulated in Table 3.1. If the complaint is environmental-related, based on the information provided by the caller (e.g. location and category of the complaint/enquiry), the PM will coordinate among different contracts, identify the responsible contractor(s) for the complaint and follow up with the responsible contractor(s) to ensure the CMP is being followed to address the complaint. The case will also be passed on from the responsible personnel to the Environmental Officer of the relevant contract for further investigation. The operation flow chart for the dedicated hotline is shown in Appendix B.
Table 3.1 List of Responsible Personnel of Each TCE Contract
Contract | Position | Party |
NL/2017/03 (C1) | Senior Resident Engineer | PM |
Public Relations Officer | BKSCTJV | |
NL/2020/02 (C2) | Resident Engineer | PM |
Site Agent | CGC | |
NL/2020/03 (C3) | Resident Engineer | PM |
Senior Public Relations Officer | BKCEL | |
Assistant Public Relations Officer | BKCEL | |
NL/2020/07 (C7) | Senior Resident Engineer | PM |
Site Agent | BKCEL | |
Sub-Agent | BKCEL | |
All contracts under the Project | Independent Environmental Checker | IEC |
All TCE contracts | Environmental Team Leader | ET |
Members of the public may choose to submit complaints on the Project to EPD via EPD’s general environmental complaint channels. All complaints referred to the ET from EPD will be recorded by the Contractor(s) and a reply will be issued to EPD to confirm receipt of the complaint by ET.
Complaint Received from Other Channels
Environmental complaints may also be received from other communication channels such as via the Community Liaison Group (CLG) and Professional Liaison Group (PLG), or referred from other sources including 1823, CEDD and the PM. All written complaints received from such other channels will be passed directly to the Contractor(s) from CEDD / the PM. For any questions or comments received from CLG / PLG members during CLG / PLG meetings, these will be responded directly in the meetings or in subsequent CLG / PLG meetings. For any other non-written complaints, the complainant will be referred to the dedicated complaint hotline and / or email channel for registering their complaint.
The Contractor of each contract maintains a record of all environmental complaints in the complaint log-book and register. A unique reference number shall be created to help track the complaint. The reference number shall be created according to the Contract reference number, date (yyyy/mm/dd) and the complaint case number. An example of the complaint reference number is shown below:
The Contractor(s) keeps the log-book and register for ET and IEC verification. The complaint log-book and register includes but is not limited to the following:
Details of the complaint received
Details of the complainant (if known)
Description of the complaint
The relevant parties for referring the complaint; and
Details of the responses and actions required/ taken
Stage 2 – Assessing the Complaint
Screening and Referring the Complaint
Once a complaint is received, the PM will coordinate among different contracts and identify the responsible contractor(s). The Contractor(s) must log, define and categorise the case as soon as possible according to the guideline in Table
Type | Description | Action | |
Environmental-related | Complaints | Complaint about environmental issues/ compliance of the construction works or site activities (e.g. dust pollution, construction plant emissions, construction noise, effluent discharge, suspended solid, oil and chemical spillage) | Responsible contractor(s) to follow the CMP to address the complaint If the Contractor(s) disagree the complaint is related to his works, the Contractor shall refer the case to PM for further analyzation and determination |
Enquiries and Suggestions | Enquiries / suggestions about environmental issues of the construction works or site activities | Contractor(s) / PM / ET to take further action (Not covered in the scope of the CMP) | |
Non-environmental-related | Complaints, enquiries and suggestions about the TCE itself that is not environmental-related | ||
Project unrelated | Complaint or enquiry not related to the TCE | ||
Table 3.2 Guideline on Categorizing Complaints, Enquiries & Suggestions Received
Acknowledging Receipt of the Environmental Complaint
Where a return postal address, fax number and / or email address of the complainant is provided, the Contractor(s) shall issue an interim reply within 3 working days to acknowledge receipt and notify the complainant of the referral of their complaint to other relevant parties where appropriate. If the complaint is referred to the ET from EPD, a reply will be issued to EPD to confirm receipt of the complaint by ET.
Stage 3 – Investigating the Complaint
If the complaint is considered to be environmental-related after screening as stated in Section 3.2.1, investigation on the complaint will proceed with the procedure stated below. As illustrated in Figure 3.2, the starting point for complaint investigation is to collect all relevant information. Based on the details of the complaint received, the Contractor(s) should collect the required information from the relevant parties, including details related to the construction activities and site conditions that may have a bearing on the complaint, as well as the mitigation measures currently implemented on site. During the complaint investigation work, the Contractor(s) shall provide all necessary information for the completion of investigation report. The ET should also review the relevant environmental monitoring data of nearby monitoring stations to ascertain if there are any associated changes or environmental exceedances that may be linked to the complaint.
Based on the aforementioned information obtained, the ET shall assess whether the source of the problem is likely to be due to the construction activities of the TCE, and also ascertain which specific works sites and / or activities are the likely causes.
To verify the information obtained and whether the source of the problem is actually due to the construction activities of the TCE, the ET should conduct site visit with Contractor(s) and actively check for the source of the problem, and whether the relevant mitigation measures have been properly implemented by the Contractor(s). The ET should also check the effectiveness and adequacy of the existing mitigation measures implemented.
Figure 3.2 Investigation Stage Process Flow Chart
Stage 4 – Resolving the Complaint
Deciding on the Appropriate Action(s)
Based on the findings of the complaint investigation described in Section 3.3, appropriate action(s), if any, should be recommended by the ET. The relevant action(s) would depend on the findings of the complaint investigation and might include the followings:
Corrective actions on mitigation measures recommended by ET, implemented by the Contractor(s)
Contractor(s) to implement additional mitigation measures after receiving recommendations in consultation with the ET, IEC and PM
Additional site visits and environmental monitoring by the ET to verify the updated situation and the effectiveness of the additional mitigation measures / corrective actions, if required
If mitigation measures are identified as required during in the investigation by the ET, the Contractor(s) should promptly carry out the mitigation works. PM should ensure that the measures have been carried out by the Contractor(s).
Preparing the Environmental Complaint Investigation report
For every environmental complaint that is confirmed to be valid and due to TCE’s activities, the ET shall compile an environmental complaint investigation report containing all the relevant information and responses from the relevant parties and the follow up actions taken.
The key areas to be covered in the environmental complaint investigation report includes but not limited to the followings:
Details of the complaint received such as received channel, date, time etc.;
Details of the complainant such as name, contact number, email etc. (if known);
Description of the complaint such as date, time, location, complaint details and circumstances etc.;
Details of the information from the relevant Contractor(s) and the investigation findings;
Details of the mitigation measures, additional monitoring and follow up actions where applicable; and
Recommendations to prevent re-occurrence of similar complaint.
If the complaint is referred from EPD, an interim report on the status of the complaint investigation and follow up actions shall be submitted to EPD by the ET. The final complaint investigation report shall be certified by the ET and verified by IEC. ET shall send the duly signed report to CEDD for information before submitting to EPD for record.
Independent audit of the complaint investigation process and the report will be conducted by the IEC. The IEC will also audit and verify the effectiveness of the existing and additional mitigation measures implemented to minimize re-occurrence of similar complaints.
Upon final acceptance of the environmental complaint investigation report, Contractor(s), PM or CEDD would provide a written response to the complainant. Also, Contractor(s) would update the record with details of the complaint investigation, follow up actions and other relevant information of the complaint in the complaint log-book. The time that would take to investigate a complaint depends on the circumstances involved and would be different for each individual case, still, a reply would be provided within 14 days from the receipt of the complaint and be provided with an update of the investigation, and would also be given the investigation results when available. For cases where the complaint is referred from EPD, the ET shall provide the final complaint investigation report (certified by the ET and verified by the IEC) to EPD for their reply to the complainant.
The ET shall also summarize the status of complaints received, including investigation findings and follow up actions taken, which shall be verified by IEC, in the monthly EM&A reports.
Environmental Complaint Handling Flow Chart
TCE’s Operation Flow Chart for Complaints Receiving from the Dedicated Complaint Hotline for the Project
Plan showing the Site Boundaries of Contracts in TCE
