Policy Comments & Advocacy

Green Power would like to draw your kind attention to our concerns about the above-captioned land use planning.

<u>General comments</u>

1. Lau Fau Shan/Tsim Bei Tsui/Pak Nai area is located within the Inner Deep Bay area and it constitutes the globally important wetland system. We opine that the proposed land use planning should prioritize ecological conservation as the primary planning principle and none ecological values within the project area should be compromised.

2. The coast and intertidal mudflat along the project area are the valuable natural landscapes within the Greater Bay Area, and they also serve as the important habitats for various species of high ecological values, including migratory birds, egretries, horseshoe crabs, sea otters, see grasses, mangroves, etc. Therefore, these natural habitats and their adjacent areas should be well preserved, and the proposed developments should not induce excessive human disturbances to these natural habitats.

3. The northern part of the project area falls into the designated Wetland Conservation Area (WCA) and Wetland Buffer Area (WBA) of the Deep Bay area according to the Town Planning Ordinance (Cap. 131, Section 16, Guideline no.12C), hence the proposed land use planning should comply with the planning intentions and requirements of WCA and WBA.

4. However, the public engagement document is too brief to understand the details of the proposed developments so that it is hard to evaluate or comment on the potential environmental impacts induced. We urge the project proponent to closely liaise with Green Groups and release up-to-date information regarding the detailed planning from time to time.

<u>Statutory environmental impact assessment (EIA)</u>

5. In view of the high ecological sensitivity of the project area, as well as the development of large-scale residential areas and mass transit system, the proposed developments are required to undergo statutory EIA processes according to the EIA Ordinance (Cap. 499). The environmental impacts induced by the proposed developments, especially to the ecological sensitive receivers, should be thoughtfully assessed, avoided and mitigated in the EIA. Area of ecological concerns should be well protected against development, pollution, eco-vandalism and human disturbance.

6. Cumulative impacts of the neighboring development projects, including but not limited to the Shui Kiu/Ha Tsuen New Development Area (HSK/HT NDA), should also be included in the EIA.

<u>Establishment of Coastal Protection Park (CPP)</u>

7. The establishment of CPP should aim at conserving the holistic wetland system at the Deep Bay area. The level of protection and control in the proposed CPP should be comparable with the existing Marine Parks. Therefore, strict statutory regulations should be accorded to combat any unfavorable human activities, such as clam digging, fishing, littering, etc.

8. The planning intention of CPP should be against development and intensive human activities in principle so that land uses such as on-farm domestic structure, bathing beach, picnic area, tent camping ground, etc. should not be permitted and strictly controlled. Any excavation or earth works (include soil dumping) and stream diversion or obtrusion should not be allowed.

9. In order to provide sufficient buffer zones for the CPP, the boundary of CPP should include the whole intertidal area (i.e. from the low-tide mark to the high-tide mark) of the coast as well as at least 100-metre extensions on seaward side beyond low-tide mark. Back shore area, vegetation and habitats above high-tide mark should also be protected.

10. The proposed CPP (landside) is split into two parts and such discontinuity opens a breach to threaten the coastal habitats and the functions of CPP. Fig. 1 shows the endangered Black-faced Spoonbill foraging at the coast of Lau Fau Shan seafood market, indicating that the coast along the proposed “Waterfront Open Space” is of high ecological values. Therefore, the proposal of building a waterfront performance venue at the waterfront area is incompatible with these important wetlands because excessive human disturbances are anticipated. We urge to change the proposed “Waterfront Open Space” into “CPP (landside)” to protect the whole continuous ecologically-sensitive coast and waterfront from Tsim Bei Tsui to Pak Nai.

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11. The management approach of the CPP is not given from the existing information. We opine that visitor control plan should be formulated to avoid exceeding the carrying capacity of CPP. Besides, only compactible environmental education or activities could be taken place at CPP.

<u>Ecological connectivity</u>

12. The boundaries of proposed residential developments adversely influence the ecological connectivity between hills and Castle Peak. We opine that high-rise buildings are incompatible with the natural landscape in Lau Fau Shan and they potentially block the flight paths of migratory birds and egrets.

13. We counter propose to reserve a blue-and-green corridor along the coast of Lau Fau Shan to enhance the ecological connectivity between Mai Po and Castle Peak.

<u>Development of eco-tourism</u>

14. Eco-tourismis distinguished from conventional or mass tourism with a distinctive operation system to be run not only commercially but also sustainably in view of use of the natural tourist resources and assets. Eco-tourism can only be achieved when the natural ecosystem and the local communities are both benefited. However, no control measures and authority are proposed to manage and surveil the operation and activities of eco-tourism. We opine that development of eco-tourism in the project area should aim at protecting the natural resources and providing financial incentives for the local people to engage with nature conservation.

15. In light of the high conservation values along the coast at Tsim Bei Tsui, we oppose building outdoor adventure park and glamping sites at the proposed “lively  eco-tourism  node” because such facilities will unavoidably induce human disturbances.

<u>Road network and transportation</u>

16. While 24% project area (i.e. 101 hectares) is allocated to road construction, the alignments of trunk roads and branch roads are not indicated in the Broad Land Use Concept Plan. We urge the project proponent to disclose the road network plan and assess whether it may induce any adverse environmental impacts. In any case, new public roads or cycling track should not intrude into ecologically sensitive areas (e.g. CPP) to induce habitat fragmentation or unnecessary disturbance.

17. Apart from road network, the proposed Green Transport Corridor along Deep Bay shore and  the Smart and Green Mass Transit System (formerly Green Transit System and Environmentally Friendly Transport Services) connecting project area and HSK/HT NDA are just loosely sketched on the Broad Land Use Concept Plan. Information about these public transportation systems, such as function, capacity, alignment, modes of construction, and etc., are not provided for further assessment on potential ecological and environmental impacts.

<u>Preservation of indigenous culture</u>

18. Some existing indigenous villages will be potentially lost due to the proposed developments. We recommend to integrate the traditional villages with the new urban development so as to preserve the indigenous culture. The history and culture of these fishing villages are valuable resources for developing eco-tourism as well.

Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).