Policy Comments & Advocacy

The Nature Conservancy (TNC), Civic Exchange and Green Power would like to share our concerns on the latest plans around the development of the Lau Fau Shan (LFS), Tsim Bei Tsui (TBT), and Pak Nai (PN) areas announced on February 21st.

The natural shores of Deep Bay, from Mai Po to Ha Pak Nai are widely recognised for their ecological importance. They house Hong Kong’s largest expanse of mangroves, seagrass beds, oyster habitats, provide critical nursing grounds for two endangered horseshoe crab species, and serve as globally important foraging grounds for migratory birds. The coastline also features rich cultural landscapes, including the traditional oyster farming industry listed under Hong Kong’s Intangible Cultural Heritage.

The area is also regionally significant, as one of the only remaining natural soft shores in the heavily reclaimed Pearl River Delta. It therefore is of utmost importance that its protection be adequately incorporated in the planning of the Northern Metropolis Development (NMD), aligning with national strategies and the Kunming-Montreal Global Biodiversity Framework 2030 for halting and reversing biodiversity loss. To that end, we believe that new protection areas like the Coastal Protection Park, including the development of quality ecotourism, present a huge opportunity for preserving natural ecosystems and the cultural landscapes that depend on them, especially as the section of coastline from TBT to Ha Pak Nai (HPN) currently sits outside of effective management.

Whilst the 2021 NMD policy document showed much promise in this regard, we would like to share some recommendations on the latest plans shared for the development of the LFS/TBT/PN areas for your consideration.

1. Preserving the ecological integrity of sensitive areas

The previous Northern Metropolis Development plan (2021) stated the establishment of a Coastal Protection Park (CPP) across 145 hectares, of which private land within Coastal Protection Area zone would be resumed and which would also include new management measures for enhanced conservation. We welcomed this initiative which showed promise for enhancing biodiversity protection along critical areas of the coastline. The new plan now only mentions the resumption of 60 hectares of land, and the Broad Land Use Concept Plan depicted in Enclosure 1 does not encompass the area between Sheung Pak Nai (SPN) and Ha Pak Nai (HPN), an area recognised for its high ecological value.

We urge the government to clarify its plans for the area between SPN and HPN, notably whether it will be covered by the CPP. This area should be atributed a high degree of protection and see the implementation of an effective management model that strongly limit impacts from visitors. Its connectivity to other protected areas, either as directly part of, or as adjacent to the CPP will be a key to safeguard its ecological function and integrity. Further, we urge the government to include the protection of the submerged seafloor adjoining the proposed protected shores (either through the CPP or other statutory zoning). These waters need to be effectively managed to ensure the integrity and ecological function of adjacent intertidal ecosystems as well as support sustainable development of the traditional oyster farming industry that depend on them.

We have the following enquiries:

• Can the government clarify whether the newly proposed CPP boundary presents a net reduction in protected area hectares (vs the intended area of 145 hectares as stated in the 2021 plan)
• What improvements in environmental conservation does new proposed CPP conceptual plan provide relative to the original conceptual plan proposed in 2021?
• Can the government clarify if the CPP will fully cover the entire intertidal area from TBT to HPN and give more details on when the public can expect to see proposed plans for the area covering SPN to HPN specifically.
• Can the government clarify whether the submerged water body of Deep Bay will be incorporated in the CPP zones or if other forms of zoning are being considered?

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2. Developing a holistic climate resilience strategy

The NMD is situated across floodplains of Deep Bay, an area that is particularly vulnerable to climate related risks. Communities across the coastal area from TBT to HPN regularly suffer great losses from flooding and severe typhoons, and these impacts are expected to worsen with climate change. With effective management, the CPP, in conjunction with the network of other proposed Wetland Conservation Parks (WCP), notably the neighbouring Hong Kong Wetland Park Extension Area and the Nam Sang Wai Wetland Park, presents a tremendous opportunity to not only enhance long-term conservation across the entire coastline, but also increase resilience of communities at the frontlines of climate related risks.

The implementation of Nature-based Solutions (NbS) defined by the IUCN global standards (2020) can play a crucial role in increasing coastal resilience while protecting biodiversity. NbS are actions to protect, sustainably manage and restore natural or semi-natural ecosystems. In this context, recommended NbS include mangrove and oyster reef restoration in the intertidal area to atenuate wave energy, reforestation of trees in Badlands around Lau Fau Shan, and the protection of natural shorelines that act as buffers and protect communities living behind them ⁽¹⁾. Regarding the plan’s stated tourism infrastructure to be developed within the CPP and the “riverine neighbourhoods” proposed as new residential zones, we are concerned that these areas are adjacent to the coast, only a few meters above sea level and considered at high risk of flooding ⁽²⁾.

With this in mind, we urge the government to conduct scenario-based climate modelling that incorporates NbS for the CPP to mitigate these risks as much as possible. More generally, we also urge the government to take a more holistic approach in the planning for climate adaptation across the NMD, and consider the CPP alongside other planned WCPs as a collective network of conservation areas that prioritize the implementation of NbS and low impact, low density activities, to enhance coastal resilience for existing communities on the frontline, while avoiding puting new populations unnecessarily in harm’s way.

We have the following enquiries:

• Has the government carried out climate modelling and/or investigated flooding scenarios for proposed development projects adjacent to the shoreline?
• Is the government planning on integrating NbS in the planning of the CPP and NMD generally?
• What does the government propose as strategies to mitigate risk of flooding for existing and new development areas?

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3. Developing a sustainable and equitable tourism industry

The planning intent places significant emphasis on "Ecotourism." Ecotourism is generally accepted as “environmentally responsible travel and visitation to relatively undisturbed natural areas, to enjoy and appreciate nature (and any accompanying cultural features) that promotes conservation, has a low negative impact on surrounding ecology and communities, and provides for beneficially active socio-economic involvement of local populations. (Source: IUCN Ecotourism Programme, 1992). TNC believes that under this definition, the development ecotourism is indeed an opportunity for enhancing protection, promoting rural revitalization, preserving socio-ecological systems along the coastline and contributing to equitable and sustainable development within the NMD. To that end, we highly support developing economic opportunities and the modernization of derelict infrastructure in LFS village, which can capitalize on its rich cultural heritage around traditional oyster farming.

On the other hand, TBT is directly adjacent to the Mai Po Ramsar nature reserve. Given its proximity, any development of ecotourism should have the lowest possible impact, contrary to which it will undoubtedly compromise the ecological integrity of the reserve. Similarly, Pak Nai is adjacent to the area covering Sheung Pak Nai (SPN) to HPN which is recognised as an ecological hotspot for endangered species, and already suffers from the impact of uncontrolled tourism. We are concerned that terms such as “lively ecotourism nodes” with “resorts”, “waterfront entertainment venues” etc. connote mass tourism vs low impact tourism and bear a high risk of detrimental impact to the surrounding ecology (notably disturbance from light pollution and raised infrastructure on wildlife and migratory birds) as well as the displacement of local communities. As such, more research is needed to fully assess potential tourism impacts in both TBT and PN areas.

We recommend that in addition to the existing EIA framework, a detailed study on tourism carrying capacity should be undertaken for more adequate planning. The government should also set specific objectives on how ecotourism activities will effectively benefit the local communities along the entire coastline as well as integrating conservation goals. To ensure equitable development we recommend engaging local communities early in planning process (instead of simply handing the task over to external developers and tourism operators).

We also recommend a “conserve first, develop later” phased development approach. By enhancing ecological function in sensitive areas prior to the disturbances they will incur, this increases ecological resilience and their ability to withstand negative impacts.

We have the following enquiries:

• Can the government clarify what standard/definition of ecotourism it will apply, whether it will carry out more detailed studies beyond the EIA framework (for e.g., Tourism carrying capacity) that are specific for assessing sustainable tourism development?
• Can the government clarify how it plans to incorporate local community interests in the management models for ecotourism areas and in the creation of new jobs?

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4. Engaging conservation stakeholders in the planning of protection areas

Since 2017, TNC and partners have been carrying out community-based conservation in Lau Fau Shan and Pak Nai to help manage, rehabilitate, and protect key areas along the coastline. We have invested heavily in science and amassed a trove of knowledge around the sustainable management of coastal resources in Deep Bay. Our inclusive community-based conservation model is proven successful in promoting collaboration amongst NGOs, academics, local community stakeholders and members of the public, and continues to provide an effective public engagement platiorm, connecting people with nature and promoting sustainable visitor practices in Pak Nai. Within the next three years, and in collaboration with all our community partners, we aim to provide management recommendations for the newly established protected area(s) that covers the entire coastline from TBT to HPN. We welcome the opportunity to assist the AFCD, the NMD task force and relevant NMD commitees in the planning exercise and recommend that the government be more proactive in engaging ecological and cultural conservation stakeholders early in the planning of conservation areas.

We look forward to working closely with the panel and the government to ensure the sustainable development of NMD that can have a positive impact for both people and nature in Hong Kong and the Greater Bay Area.

Thank you for your consideration.