Agriculture, Fisheries and Conservation Department
5/F Cheung Sha Wan Government Offices,
303 Cheung Sha Wan Road, Kowloon
(E-mail: myviews_cpp@afcd.gov.hk)
Green Power welcomes the Government's initiative to establish a Coastal Protection Park (CPP) at Tsim Bei Tsui, Lau Fau Shan and Pak Nai, as proposed in the Initial Concept and Management Plan (the Plan). The CPP should act as a "Coastal Landscape Ecological Corridor" that protects the globally important Inner Deep Bay wetland system and its associated biodiversity. However, while the overall vision is laudable, the current proposal as presented is insufficiently detailed and, in several critical aspects, falls short of what is necessary to achieve effective and enforceable conservation. We would like to draw your attention to the following comments for your consideration.
General Comments
1. We are encouraged by the proposed CPP area of approximately 2,370 hectares, which includes a substantial seaside portion. However, the true measure of this park's success will be the effectiveness of its management and zoning. The Plan remains high-level and lacks the concrete details, legally binding designations, and enforcement mechanisms essential for safeguarding the area's irreplaceable ecological value and capacity to support the ecologically compatible oyster farming.
2. The CPP should be established with ecological conservation as its fundamental principle. As we have previously stressed in our comments on the Developments at Lau Fau Shan, Tsim Bei Tsui and Pak Nai Areas, the entire coastal and intertidal wetland system is of international significance and is integral to the Mai Po Inner Deep Bay Ramsar Site. The establishment of the CPP must not be used to justify or facilitate detrimental development elsewhere in the project area. To ensure holistic protection, we urge the Government to make the detailed zoning plans, management strategies and statutory regulations for the CPP publicly available before the Study Brief (under Environmental Impact Assessment Ordinance) and statutory landuse plans (under Town Planning Ordinance) for the associated Developments is/are issued, so that stakeholders can provide fully informed input and the integrity of the EIA and town planning process is enhanced.
Ecology and Habitat Protection
3. The key objectives of the Plan to identify "Nature Conservation" and "Protect coastal ecosystem, intertidal mudflats in particular" is welcome. However, the Plan must explicitly identify and provide robust protection for all known species of high conservation value within the proposed CPP, including the Eurasian Otter (now confirmed present in the Project Profile), Chinese and Mangrove Horseshoe Crabs, seagrass beds (including Halophila beccarii), migratory waterbirds and egretries. The proposed Biodiversity Conservation Zone (Level 1) must encompass these critical habitats in their entirety, and the statutory protection afforded to them must be at least equivalent to that of existing Marine Parks.
4. The Plan refers to a "zonation management" approach. We strongly recommend a clear hierarchy of protection based on the seven guiding principles set out in the joint green group submission of 22 October 2025. Specifically:
o Protection Level 1 – Core Conservation Zones: The intertidal mudflats at Pak Nai and Tsim Bei Tsui (particularly the areas currently designated as SSSIs) must be designated as Core Conservation Zones. These areas should be managed as "no-go" zones for the public to protect fragile habitats (e.g., horseshoe crab nurseries, seagrass beds) from trampling and disturbance. Larger-scale infrastructure must be avoided, and only minimal, carefully assessed educational facilities should be permitted. This zoning would align with the Government's commitment to expanding Marine Protected Areas (MPAs) under the Biodiversity Strategy and Action Plan (BSAP).
o Protection Level 2 – Biodiversity Management and Wise-use Zones: This should cover the majority of the seaside CPP (including the subtidal areas of STT 2266) and parts of the landside CPP. Here, activities like sustainable oyster farming and controlled ecotourism could occur, provided they are subject to strict, science-based management. Active habitat management, including invasive species control (Spartina sp., Sonneratia spp.) and marine litter removal, must be implemented. Backshore vegetation and proposed Green Trail should be considered to be included in these zones.
o Protection Level 3 – Buffer Zones: Other areas within CPP and areas adjacent to the CPP with existing hard infrastructure (e.g., roads, villages) should be designated as Buffer Zones where stringent measures are enforced to mitigate water, noise and light pollution impacts on the surrounding ecology. Backshore vegetation and proposed Green Trail should be considered to be included in Buffer Zones.
Backshore Vegetation and Green Trail
5. The existing backshore habitats (at higher altitude than existing intertidal zone and mangroves) and terrestrial vegetation along the coastline should be preserved in their entirety. Backshore vegetation provides an essential ecosystem service by filtering and reducing pollutants and sediment loads from surface urban runoff before it reaches the intertidal mudflats and oyster beds. Furthermore, it enhances climate resilience against coastal erosion and storm surges. As the inland areas undergo intense development, maintaining a wide, natural, vegetated backshore buffer within the CPP is critical to complying with the "zero discharge policy" for Deep Bay, providing climate resilience for properties and infrastructures and maintaining natural backdrop for future developments.
6. The Plan proposes a Green Trail but must ensure that all visitor infrastructure, including boardwalks, bird hides and trails, is designed and located to avoid any fragmentation or disturbance to sensitive habitats and wildlife corridors. The alignment of any new transport infrastructure within or adjacent to the CPP must be rigorously assessed to ensure it does not act as a barrier to wildlife movement, especially for otters and terrestrial fauna. The ecological connectivity between the CPP, the Mai Po Ramsar Site and the proposed Hong Kong Wetland Park Expansion Area must be maintained and enhanced.
7. We hold grave reservations regarding potential engineering works within or adjacent to the CPP. Any marine or intertidal works—including minor modifications, maintenance, or demolition of structures for safety or local enhancement—must be kept to an absolute minimum. The construction of heavy tourist infrastructure, extensive boardwalks, or permanent visitor centers inside sensitive habitats will induce irreversible direct loss and fragmentation. All required administrative and educational installations should be positioned outside the ecological boundaries within less sensitive buffer zones.
Management and Enforcement
8. We are concerned that the Plan proposes a mix of management modes including "land use planning and control" and "public-private partnership". While these can be effective, they are often insufficient for the highest-value conservation zones. The Administration must guarantee that the Core Conservation Zones (Level 1) are placed under a statutory framework that provides legal protection and clear enforcement authority, comparable to that of a Marine Park or Country Park. Reliance on non-statutory measures for the most sensitive areas are inadequate and non-enforceable and would leave the park’s core assets vulnerable. Such conservation measures and facilities must be established in prior to the commencement of other development works surrounding CPP.
9. The proposed "Eco-Learning and Discovery Zone" on the landside has potential for environmental education. However, its development must be strictly controlled. It must not be over-developed, and its design must prioritise conservation, acting as a buffer to the more sensitive intertidal areas. Any "leisure fisheries" must be demonstrably sustainable and operated in a manner that does not harm water quality, sensitive habitats, planned or existing identified ecologically important areas or biodiversity.
10. Stringent statutory regulations, equivalent to those governing Marine Parks and Country Parks, must be enacted to deter littering, wildlife disturbance, and unauthorized access. A certified eco-guide system and a strict visitor quota system is recommended for sensitive sectors of the park.
11. The EIA for the surrounding developments must thoroughly address the cumulative impacts of light, noise, and air pollution on the CPP. High-rise developments nearby must be strictly regulated to maintain the vital avian flight paths between Mai Po, the CPP, and Castle Peak. Additionally, given that the Northwest New Territories is a known fly-tipping blackspot, the construction phase of neighboring developments introduces extreme risks of illegal dumping of solid and liquid waste into the streams feeding the CPP. Mandatory real-time GPS tracking of all dump trucks and strict fencing of the CPP boundaries must be integrated into works contracts.
Eco-tourism and Carrying Capacity
12. The Plan promotes eco-recreation and education as a key objective, but, as we have previously noted, it provides no definition, strategy or management framework. "Eco-tourism", without clear and scientific definition, is not automatically benign and can severely degrade natural assets if unmanaged. A detailed ecological carrying capacity assessment must be undertaken for the entire CPP before any specific tourism (not limited to eco-tourism) activities or facilities are finalised. This must be complemented by a regular, science-based monitoring programme to assess environmental performance and a surveillance mechanism with clear, enforceable operating conditions. Without these, the promotion of "eco-tourism" remains a vague and potentially damaging concept.
Oyster Farming and Community Engagement
13. We support the Plan's recognition of the cultural and economic importance of traditional oyster farming. The proposal to include STT 2266 for streamlined management is a positive step. We reiterate our recommendation to develop best management practices for restorative oyster farming, which includes optimising raft density within ecological carrying capacity and establishing a centralized oyster shell recycling scheme to address unsustainable disposal on the shoreline.
Sustainable Conservation Financing
14. We urge the Administration to develop a robust and sustainable financial model to support the operation and administration of the CPP, including but not limited to liaison of stakeholders, compliance with statutory requirements, crowd/traffic control, scientific monitoring, surveillances and patrolling, propaganda, etc.
Thank you for your kind attention. Green Power remains committed to working constructively with the Government and all stakeholders to ensure the Coastal Protection Park becomes a world-class example of successful and sustainable conservation. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).
Green Power welcomes the Government's initiative to establish a Coastal Protection Park (CPP) at Tsim Bei Tsui, Lau Fau Shan and Pak Nai, as proposed in the Initial Concept and Management Plan (the Plan). The CPP should act as a "Coastal Landscape Ecological Corridor" that protects the globally important Inner Deep Bay wetland system and its associated biodiversity. However, while the overall vision is laudable, the current proposal as presented is insufficiently detailed and, in several critical aspects, falls short of what is necessary to achieve effective and enforceable conservation. We would like to draw your attention to the following comments for your consideration.
General Comments
1. We are encouraged by the proposed CPP area of approximately 2,370 hectares, which includes a substantial seaside portion. However, the true measure of this park's success will be the effectiveness of its management and zoning. The Plan remains high-level and lacks the concrete details, legally binding designations, and enforcement mechanisms essential for safeguarding the area's irreplaceable ecological value and capacity to support the ecologically compatible oyster farming.
2. The CPP should be established with ecological conservation as its fundamental principle. As we have previously stressed in our comments on the Developments at Lau Fau Shan, Tsim Bei Tsui and Pak Nai Areas, the entire coastal and intertidal wetland system is of international significance and is integral to the Mai Po Inner Deep Bay Ramsar Site. The establishment of the CPP must not be used to justify or facilitate detrimental development elsewhere in the project area. To ensure holistic protection, we urge the Government to make the detailed zoning plans, management strategies and statutory regulations for the CPP publicly available before the Study Brief (under Environmental Impact Assessment Ordinance) and statutory landuse plans (under Town Planning Ordinance) for the associated Developments is/are issued, so that stakeholders can provide fully informed input and the integrity of the EIA and town planning process is enhanced.
Ecology and Habitat Protection
3. The key objectives of the Plan to identify "Nature Conservation" and "Protect coastal ecosystem, intertidal mudflats in particular" is welcome. However, the Plan must explicitly identify and provide robust protection for all known species of high conservation value within the proposed CPP, including the Eurasian Otter (now confirmed present in the Project Profile), Chinese and Mangrove Horseshoe Crabs, seagrass beds (including Halophila beccarii), migratory waterbirds and egretries. The proposed Biodiversity Conservation Zone (Level 1) must encompass these critical habitats in their entirety, and the statutory protection afforded to them must be at least equivalent to that of existing Marine Parks.
4. The Plan refers to a "zonation management" approach. We strongly recommend a clear hierarchy of protection based on the seven guiding principles set out in the joint green group submission of 22 October 2025. Specifically:
o Protection Level 1 – Core Conservation Zones: The intertidal mudflats at Pak Nai and Tsim Bei Tsui (particularly the areas currently designated as SSSIs) must be designated as Core Conservation Zones. These areas should be managed as "no-go" zones for the public to protect fragile habitats (e.g., horseshoe crab nurseries, seagrass beds) from trampling and disturbance. Larger-scale infrastructure must be avoided, and only minimal, carefully assessed educational facilities should be permitted. This zoning would align with the Government's commitment to expanding Marine Protected Areas (MPAs) under the Biodiversity Strategy and Action Plan (BSAP).
o Protection Level 2 – Biodiversity Management and Wise-use Zones: This should cover the majority of the seaside CPP (including the subtidal areas of STT 2266) and parts of the landside CPP. Here, activities like sustainable oyster farming and controlled ecotourism could occur, provided they are subject to strict, science-based management. Active habitat management, including invasive species control (Spartina sp., Sonneratia spp.) and marine litter removal, must be implemented. Backshore vegetation and proposed Green Trail should be considered to be included in these zones.
o Protection Level 3 – Buffer Zones: Other areas within CPP and areas adjacent to the CPP with existing hard infrastructure (e.g., roads, villages) should be designated as Buffer Zones where stringent measures are enforced to mitigate water, noise and light pollution impacts on the surrounding ecology. Backshore vegetation and proposed Green Trail should be considered to be included in Buffer Zones.
Backshore Vegetation and Green Trail
5. The existing backshore habitats (at higher altitude than existing intertidal zone and mangroves) and terrestrial vegetation along the coastline should be preserved in their entirety. Backshore vegetation provides an essential ecosystem service by filtering and reducing pollutants and sediment loads from surface urban runoff before it reaches the intertidal mudflats and oyster beds. Furthermore, it enhances climate resilience against coastal erosion and storm surges. As the inland areas undergo intense development, maintaining a wide, natural, vegetated backshore buffer within the CPP is critical to complying with the "zero discharge policy" for Deep Bay, providing climate resilience for properties and infrastructures and maintaining natural backdrop for future developments.
6. The Plan proposes a Green Trail but must ensure that all visitor infrastructure, including boardwalks, bird hides and trails, is designed and located to avoid any fragmentation or disturbance to sensitive habitats and wildlife corridors. The alignment of any new transport infrastructure within or adjacent to the CPP must be rigorously assessed to ensure it does not act as a barrier to wildlife movement, especially for otters and terrestrial fauna. The ecological connectivity between the CPP, the Mai Po Ramsar Site and the proposed Hong Kong Wetland Park Expansion Area must be maintained and enhanced.
7. We hold grave reservations regarding potential engineering works within or adjacent to the CPP. Any marine or intertidal works—including minor modifications, maintenance, or demolition of structures for safety or local enhancement—must be kept to an absolute minimum. The construction of heavy tourist infrastructure, extensive boardwalks, or permanent visitor centers inside sensitive habitats will induce irreversible direct loss and fragmentation. All required administrative and educational installations should be positioned outside the ecological boundaries within less sensitive buffer zones.
Management and Enforcement
8. We are concerned that the Plan proposes a mix of management modes including "land use planning and control" and "public-private partnership". While these can be effective, they are often insufficient for the highest-value conservation zones. The Administration must guarantee that the Core Conservation Zones (Level 1) are placed under a statutory framework that provides legal protection and clear enforcement authority, comparable to that of a Marine Park or Country Park. Reliance on non-statutory measures for the most sensitive areas are inadequate and non-enforceable and would leave the park’s core assets vulnerable. Such conservation measures and facilities must be established in prior to the commencement of other development works surrounding CPP.
9. The proposed "Eco-Learning and Discovery Zone" on the landside has potential for environmental education. However, its development must be strictly controlled. It must not be over-developed, and its design must prioritise conservation, acting as a buffer to the more sensitive intertidal areas. Any "leisure fisheries" must be demonstrably sustainable and operated in a manner that does not harm water quality, sensitive habitats, planned or existing identified ecologically important areas or biodiversity.
10. Stringent statutory regulations, equivalent to those governing Marine Parks and Country Parks, must be enacted to deter littering, wildlife disturbance, and unauthorized access. A certified eco-guide system and a strict visitor quota system is recommended for sensitive sectors of the park.
11. The EIA for the surrounding developments must thoroughly address the cumulative impacts of light, noise, and air pollution on the CPP. High-rise developments nearby must be strictly regulated to maintain the vital avian flight paths between Mai Po, the CPP, and Castle Peak. Additionally, given that the Northwest New Territories is a known fly-tipping blackspot, the construction phase of neighboring developments introduces extreme risks of illegal dumping of solid and liquid waste into the streams feeding the CPP. Mandatory real-time GPS tracking of all dump trucks and strict fencing of the CPP boundaries must be integrated into works contracts.
Eco-tourism and Carrying Capacity
12. The Plan promotes eco-recreation and education as a key objective, but, as we have previously noted, it provides no definition, strategy or management framework. "Eco-tourism", without clear and scientific definition, is not automatically benign and can severely degrade natural assets if unmanaged. A detailed ecological carrying capacity assessment must be undertaken for the entire CPP before any specific tourism (not limited to eco-tourism) activities or facilities are finalised. This must be complemented by a regular, science-based monitoring programme to assess environmental performance and a surveillance mechanism with clear, enforceable operating conditions. Without these, the promotion of "eco-tourism" remains a vague and potentially damaging concept.
Oyster Farming and Community Engagement
13. We support the Plan's recognition of the cultural and economic importance of traditional oyster farming. The proposal to include STT 2266 for streamlined management is a positive step. We reiterate our recommendation to develop best management practices for restorative oyster farming, which includes optimising raft density within ecological carrying capacity and establishing a centralized oyster shell recycling scheme to address unsustainable disposal on the shoreline.
Sustainable Conservation Financing
14. We urge the Administration to develop a robust and sustainable financial model to support the operation and administration of the CPP, including but not limited to liaison of stakeholders, compliance with statutory requirements, crowd/traffic control, scientific monitoring, surveillances and patrolling, propaganda, etc.
Thank you for your kind attention. Green Power remains committed to working constructively with the Government and all stakeholders to ensure the Coastal Protection Park becomes a world-class example of successful and sustainable conservation. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).
Yours faithfully,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power
Yours faithfully,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power
