Policy Comments & Advocacy

1. The Sustainable Lantau Office (SLO) of the Civil Engineering and Development Department (CEDD) proposed to “develop sustainable leisure and recreation in Cheung Sha and Shek Pik, ecologically and naturally education-based facilities in Shui Hau and Pui O (i.e. the South Lantau Eco-creational Corridor (the Proposal))…together with ancillary facilities such as strengthen the transport and accommodation, etc.” as recommended by their previous related studies.

2. Ten green groups are gravely concerned about the objectives and environmental and ecological impacts of the Proposal, particularly loss of natural assets for “eco-recreation”, and pollution and habitat damages brought about by overloading of environmental capacity of South Lantau by increased road traffic and visitor facilities.

Conservation not a slogan

3. Dedicated to the overarching principle of “Development in the North, Conservation for the South” embraced in the Sustainable Lantau Blueprint promulgated in 2017, the planning proposals for South Lantau should be in favour of conservation priority. Green groups would like to stress this can only be achieved through a conservation-oriented, rather than demand-oriented, planning strategy for South Lantau. Policies ensuring safety and avoiding disturbance to local communities and ecosystems, pollution, dumping and incompatible developments on South Lantau should be in place prior to any recreation, tourism and transportation demands on Lantau.

4. Hence, the feasibility of the Proposal should be well justified in the first place with the following statutory and/or administrative requirements:

(a) There should be compliance with existing conservation, environmental protection and town planning ordinances, including the Town Planning Ordinance, the Country Park Ordinance, the Wild Animals Protection Ordinance, the Water Pollution Control Ordinance, the Environmental Impact Assessment Ordinance (EIAO), etc.

(b) Visitor and environmental carrying capacities of locations in the “corridor” should be assessed. The scale, site selection, design and operation of related developments, facilities, ancillary and transport facilities should be benchmarked against these carrying capacities.

(c) Conservation and education should be accorded higher priority than recreation, and natural ecological resources and environmental quality should not be compromised and, indeed, should be enhanced. The construction and operation of the related facilities and infrastructures should not impose insurmountable and irreversible adverse impacts to the environment and valuable habitats, species and landscapes.

(d) Different objectives set in “Hong Kong Biodiversity Strategy and Action Plan 2016-2021”⁽¹⁾ should also be considered to achieve in addition to “Area 4 – Promoting community involvement”.

5. Although “protect natural ecological resources” is the first planning principle in the proposal, no corresponding strategy, control or measures are planned to manifest this key principle.

(a) No natural ecological resources are identified in the Proposal, although sensitive habitats or species should not be publicized. In this regards, developments and civil engineering works should be prohibited in natural rivers/streams (including their mouths), wetlands, bird and butterfly hotspots, Fung Shui woods and mature woodlands.

(b) Despite being billed as an “eco” proposal, only developments but not conservation measures are proposed, and some proposed facilities will obviously impose significant ecological and environmental impacts.

(c) The issue of feral cattle and buffaloes is totally neglected in the Proposal. There are herds of cattle and buffaloes inhabiting South Lantau. If no proper measures are proposed to relieve potential conflicts among human, feral cattle and buffaloes, they may disturb the visitors, cause damage to facilities and properties, and feed on food waste, which may profoundly alter the outcomes of the Proposal. The ecological significance of feral cattle and buffaloes for South Lantau, especially wetland habitats (e.g. Pui O, and Shui Hau) should be recognised with adequate measures and strategy.

(d) Neither strategy nor measures are proposed for “ecotourism” to ensure the eco-recreational activities will not harm the biodiversity and ecosystems.

(e) No assessment of environmental carrying capacity has been conducted for the Proposal; it may be that excessive visitors, inadequate facility design and lack of environmental infrastructures will harm the biodiversity and ecosystems.

South Lantau Biodiversity and Ecosystems

6. It is disappointing that no measures have been recommended to avoid disturbing the sensitive habitats and species in South Lantau. The idea to promote the leisure and recreational facilities “suitable for use and enjoyment in all seasons” simply reveals the negligence regarding seasonal vulnerability of some important natural ecological resources, such as the wintering butterflies, breeding season of Horseshoe Crabs, peak seasons for migratory birds.

7. A local green group has conducted odonate surveys⁽²⁾ in Shui Hau, Tong Fuk, Cheung Sha and Pui O from 2015 to 2021. The number of odonate species recorded in the 4 sites ranged from 30-46, which showed high diversity of odonates in these 4 sites (Appendix 1). Among them the Mangrove Skimmer (Orthetrum poecilops) listed as “Vulnerable” by IUCN Red List of Threatened Species was recorded in Shui Hau.

8. Furthermore, the green group found that Shui Hau & Tong Fuk is a butterfly hotspot⁽³⁾. From 2019 to 2023, 136 species of butterflies were recorded in Shui Hau & Tong Fuk (Appendix 2) which are almost half of the total number of species in Hong Kong. Among these 136 species, 10 and 14 species are ranked as “Very Rare” and “Rare” respectively including Forget-me-not (Catochrysops strabo) and Golden Birdwing (Troides aeacus).

9. Apart from butterfly hotspot, the green group also found that Shui Hau has been a spot for wintering butterfly. The average annual number of butterfly recorded is 92.9 for survey transects, which is ranged from 41 to 191 in 2014-2023.

10. Over 240 and 208 bird species have been recorded at Pui O and Shui Hau, respectively, indicating a very high bird diversity⁽⁴⁾. These sites also provide important wetland and open country habitats for bird species of conservation concern, such as the globally critically endangered Yellow-breasted Bunting (Emberiza aureola), endangered Siberian Sand Plover (Charadrius mongolus), vulnerable Chinese Egret (Egretta eulophotes), and Von Schrenck’s Bittern (Ixobrychus eurhythmus) of Regional Concern. All these areas should be reserved for nature conservation.

Beach Water Quality as Indicator of Development

11. Regarding bathing season geometric mean of E. coli levels of Hong Kong's gazetted beaches in 2023⁽⁵⁾, although all the four bathing beaches in the Proposal were graded “Good”, annual ranking of Upper Cheung Sha, Tong Fuk, Lower Cheung Sha and Pui O were ranked 7, 10, 27 and 28 respectively, and the ranking of Lower Cheung Sha and Pui O is very marginal.

12. For weekly grading in 2023, Lower Cheung Sha had only 29% graded “Good” but 68% “Fair” which was much worse than the others, i.e. Pui O (71% “Good”, 26% “Fair”), Upper Cheung Sha (94% “Good”, 3% “Fair”) and Tong Fuk (100% “Good”). Also, a regional water quality fluctuation associated with a heavy rainstorm was observed in the district in early May 2023, when Lower Cheung Sha Beach, Upper Cheung Sha Beach, Pui O Beach were downgraded to “Very Poor”.

13. The water quality of the bathing beaches is listed in the following table for comparison.

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14. These figures are presented not for revealing the suitability of bathing beaches for recreational purposes, but for demonstrating that the developments/settlement in the catchment of bathing beaches will cause a deterioration in the water quality by raising E. Coli levels. Among the four beaches, the catchments of Pui O and Lower Cheung Sha are more populated and peppered with brown-field operations.

Lower and Upper Cheung Sha

15. As a proposed landmark visitor centre will provide a full range of ancillary facilities, including catering, retail, and sight-seeing, as well as indoor and outdoor venues for hosting various events throughout the year (such as markets), the beach water quality in the vicinity, especially Lower Cheung Sha, will very likely deteriorate. We opine that a comprehensive sewage strategy, and sewerage and stormwater drainage upgrading plan should be devised and implemented in prior to any related developments to safeguard a decent recreational natural resource for dynamic activities, such as surfing and kayaking, or passive activities such as beach strolls, etc.

16. A comprehensive sewage strategy, and sewerage and stormwater drainage upgrading plan should be expanded to cover Upper Cheung Sha. The scale and visitor capacity of these facilities should be effectively restricted to protect the pristine environment and particularly the water quality of its bathing beach which is proposed to provide a diverse range of water-based leisure and recreational activities and ancillary facilities, including a new water sports and recreation centre, leisure and adventure water sports zones, a beach campsite and a leisure pier, etc.

17. Barrier-free beach walkway and the proposed facilities along the walkway, including a parent-child playground, sitting-out area, versatile beach event venue are proposed along Upper and Lower Cheung Sha Beaches. However, these beach facilities will encroach on the natural backshore vegetation.

18. The backshore natural vegetation constitutes a narrow and unique habitat between the coast/beaches and the inland which will filter surface runoff during rainstorm and even curb aggravating storm surge under climate change. Such natural backshore habitat in Hong Kong has been substantially lost due to reclamation, road development and clearance for visitor facilities or manmade landscaping. Fortunately, natural backshore habitat remains intact in most part of South Lantau coast, and should be protected and its values and functions should be well recognized.

19. Backshore habitat has high values in terms of biodiversity⁽⁶⁾, stabilizing beach substratum stability and improving water quality. We urge to conduct ecological survey for the backshore habitats and preserve the backshore habitat and its associated vegetation. Carparks should not be built in the backshore zone, to avoid loss of habitat, and reduce the risk of soil contamination and water pollution with fuels, lubricating oil, detergents, etc.

20. On the other hand, provision of catering services and increase in visitors will generate more floating refuse (especially plastic waste) which will impose hygiene problems for water sports players, ecological risks for marine life and will be an eyesore for the public wishing to enjoy the beautiful beach scenery.

21. Slopes on South Lantau are one of the major areas of colluvium in Hong Kong and serious landslide incidents occurred frequently⁽⁷⁾. Massive vegetation clearance and extensive slope works will be needed for establishing an adventure vacation area, with adventure facilities of different levels of excitement (such as rope adventures), uphill chairlifts, and quality holiday accommodations, etc. on hillside on the green belt areas to the north of South Lantau Road in Upper Cheung Sha. In view of the steepness of these hillsides, the risk of landslide will be elevated, especially when vegetation is removed, and colluvium is loosened and exposed to precipitation without the protection of mature trees and other vegetation. In order to stabilize the exposed hillside, extensive slope work is needed to safeguard South Lantau Road and planned facilities on the coast of Upper Cheung Sha.

22. Without the filtration effect of vegetation, the polluted surface runoff of the planned facilities on hillside will be flushed directly or drained through stormwater drainage to the beach, and degrade the water quality. Also, extensive concrete or manmade slope surfaces will ruin the scenery of emerald green mountains to the north of South Lantau Road.

Shek Pik

23. The exact alignment of Shek Pik Heritage Trail was not proposed; it may locate in Lantau South Country and water gathering ground of Shek Pik Reservoir. Given there is no existing footpath encircling the reservoir, the proposed heritage trail may require heavy civil engineering works that may encroach on the existing catchwater (adjoining western end of the main dam) and natural streams. Ecological and environmental impact assessments should be conducted, under the scope of EIAO.

24. The provision of ancillary and transportation facilities for Village Cultural Tour and cultural and artistic installations is not mentioned in the Proposal, yet may result in significant environmental and ecological impacts.

Shui Hau

25. Same concern as beach walkway connecting Lower and Upper Cheung Sha, we gravely concerned about the encroachment on the highly ecological sensitive sandflats and associated backshore by the proposed sandflat walkway at Shui Hau.

26. Also, no measures are proposed to protect the ecologically sensitive sandflats, including to safeguard shellfish, horseshoe crabs and migratory birds such as shorebirds. There are also no indications of any measures to restrict misbehaviour by visitors and avoid excessive visitors.

Pui O

27. Treetop walkway is quite new to Hong Kong. Regarding the proposed Pui O Treetop Education Corridor, feasibility study is required to evaluate ecological impacts of this facility in both construction and operation phase. Woodlands with high ecological values should be avoided. The aim of the treetop walkway should be for environmental education rather than adventure.

28. As there is no precedent operation of similar scale in Hong Kong, the involved footprint should be kept small scale, first to evaluate its ecological and environmental impacts before considering extension.

29. Health and structural conditions of trees involved in the facilities should be closely monitored, to avoid adverse impacts to trees. A proper management plan should be formulated to secure the user safety and other impacts of the facilities.

30. In view of the existing problems of campsite in South Lantau, we disagree with the proposed Glamping Sites on the hillside of Pui O. Such a facility subjects the countryside to incompatible travel lifestyle, i.e. abusive use of electricity for lighting, unnecessary air-conditioning and refrigeration, playing loud music, heavy use of detergents/disposable products, which deviate from the planning principle of “introduce sustainable, ecologically and naturally based recreational facilities that are in harmony with the local environment”. Such activities also act contrarily to the planning principle “introduce biodiversity and learn about the natural ecology through experience education”.

31. Currently, camping on unauthorized camping sites has led to various environmental problems (e.g. refuse, hygiene, noise and light pollution) and habitat damage (e.g. direct and indirect loss in wetlands). Operation of campsites are highly depended on “self-discipline” of users, resulting in poor waste and sewage management due to the misconduct of users. Nature incompatible behaviours are observed frequently, e.g. collection of clams, discharge of wastewater, noise etc. Thus, existing problems of campsites in South Lantau need to be recognised and addressed before setting up more campsites, to prevent environmental and ecological impacts of visitors’ misbehaviours from proliferating to other undisturbed parts of South Lantau under the Proposal.

32. More importantly, provision of ancillary and transport facilities of glamping/camping sites will trigger unplanned and incompatible development of campsites in neighbouring the sites under the Proposal. Even worse, these sites may encroach on wetlands or other habitats, leading to loss of biodiversity, environmental and flooding impacts.

Catering Services

33. If catering services are proposed, waste disposal, water pollution and issue of wildlife feeding on refuse should be addressed. “Avoid and reduce waste at source” should be the message conveyed in “eco-recreation corridor”. Waste reduction measures should be implemented (e.g. prohibit disposable eating utensils, set up water dispenser, etc.).

34. Take-away food services should be avoided as far as possible in order not to introduce food packaging wastes. The chance for the wildlife to access human food will also be lowered.

35. While catering services will produce lots of waste and sewage, proper waste and sewage treatment must be available to secure environmental hygiene, protect water quality of natural streams and water gathering grounds, and deter wildlife’s feeding.

36. Comprehensive waste recovery and treatment strategy should be devised aiming at maintaining a neat and hygienic environment for residents and visitors, and eliminating waste pollution and floating refuse. Sufficient smart bins for food waste and devices (e.g. metal fences) to deter the feral cattle and buffaloes from reaching catering areas and waste collection facilities should be installed. GREEN@COMMUNITY should be stationed in Proposal area to serve the resident communities and visitor facilities.

Transport and Traffic

37. Transport and traffic strategy is of ultimate importance to safeguard the pristine environment and landscape, as well as fragile and unique ecology of South Lantau. We strongly recommend maintaining the existing vehicle restriction measures in South Lantau. Visitors are encouraged to use public transport to visit South Lantau.

38. Lantau Closed Road Permits should be strictly enforced, especially for heavy vehicles and trucks, to safeguard bikers and pedestrians, and lower the risks of fly-tipping and incompatible developments.

39. Sha Tau Kok serves as a vivid example of how opening up Closed Roads will lead to environmental destruction. Sha Tau Kok was a Frontier Closed Area, where only vehicles and persons with permits could enter. After the opening of the area in 2012, Sha Tau Kok became a tourist hotspot and many of the previously green areas were converted into car parks. In addition, large areas of freshwater wetlands were reclaimed and levelled by landowners with the expectation that property values would rise in future. Not only were these former farmland areas damaged, mangrove forests along the coast were also threatened. Comparing aerial photos of the Frontier Closed Area in 2006 and 2012, 50% increase in levelled land in Sheung Tam Shui Hang, and a 20% increase in Ha Tam Shui Hang were seen. Although ordinances are currently in place aiming at prevention of environmental vandalisms, they are in many cases ineffective or difficult to enforce, resulting in uncontrollable and non-enforceable environmental vandalism and nuisance that leads to irreversible loss of valuable natural and tourist resources to pollution, illegal dumping, visual blight and incompatible developments in Sha Tau Kok. (extracted from Joint Green Groups’ Appeals for a Green Transport and Traffic Strategy on Lantau, 31 Aug, 2016)

40. Similar environmental vandalism cases have been happening in Tung Chung River valley on Lantau, mostly at Shek Lau Po and Shek Mun Kap, since the relaxation of traffic restrictions along Tung Chung Road. Although such cases have led to complaints to the Administration, minimal enforcement actions were taken, and the results of the vandalism are hard to restore.

41. Regarding the Proposals, we opine all roads in South Lantau and Tung Chung Road south of Shek Mun Kap should be maintained as Closed Roads in order to protect the ecology, natural and tourist resources in South Lantau.

42. In view that the public transport connections will be strengthened, daily quota of “Driving on Lantau Island” for private cars to access all roads in South Lantau should not be relaxed, in order not to cause unfavourable environmental impacts e.g. air and water pollution, noise nuisance & etc. Without pressing reasons, no additional quotas for private cars to access all roads in South Lantau should be issued on Saturdays, Sundays and public holidays.

43. The number of additional parking spaces and charging facilities for private cars should be strictly limited to avoid additional traffic loading and congestion on South Lantau Road that will lower the convenience and efficiency of public transport.

44. We are concerned about the road safety of bikers, pedestrians, buffaloes and cattle using roads in South Lantau and Tung Chung Road. We urge that the driving speed of all vehicles must be limited to a safe speed and measures in place to enforce that.

45. The decision to build a pier at Cheung Sha should be carefully reviewed. Due to the geological limitations and the construction standard, the pier will have a large footprint for standard-sized ferries or Kai To. The scale and location of the pier and ferry services should be studied with consideration of environmental and visitor carrying capacity, and sustainability. The impacts of associated marine traffic on marine wildlife such as Finless Porpoise should be assessed.

Summary

46. Regarding the Planning Principle “Protect natural ecological resources”, the biodiversity and ecosystems of each area in the “corridor” should be well identified and endorsed by relevant authorities, experts and conservation/green groups. Relevant monitoring and protection measures for identified natural ecological resources should be devised and managed independently (in terms of administration and financial support) of operators/owners of recreation facilities. An effective and efficient coordination mechanism should be established among stakeholders. Enforceable regulatory measures should be in place to keep check on the environmental and ecological impacts of the recreational facilities.

47. Assessing the carrying capacity and limiting visitor numbers are essential for South Lantau areas. Activities with large number of visitors are not compatible with the ecological and environmental conditions of these areas. The Proposals can fulfil the aim to let visitors to enjoy the natural ecological resources only if the number of visitors is restricted within the environmental carrying capacity.

48. The proposed visitor centre, water sports and recreation centre, education centre, and other large building structures should be located at or around developed areas with low ecological values. It is not sustainable to attract excessive numbers of visitors to pristine and relatively pristine countryside areas in South Lantau.

49. Environmental and ecological assessments should be conducted for the proposed barrier-free beach walkway, heritage trail, sandflat walkway, treetop walkway and other pathways which should be constructed in an environmentally friendly way with minimum footprint. The pathways should not lead the visitors to environmental sensitive areas or areas with high ecological value.

50. The proposed adventure facilities of different levels of excitement (such as rope adventures) and uphill chairlifts seem not in line with the principle of “Development in the North, Conservation for the South”. Construction of such facilities requires a large footprint. We recommend excluding these adventure facilities.

51. Regarding the Planning Principle “…improve the accessibility and connectivity of the attractions”, the Administration must be aware that accessibility is always the perverse incentive to eco-vandalism, pollution and loss of natural ecological and heritage resources in rural and countryside areas in Hong Kong. The administration must clearly position and proclaim that the natural ecological and heritage resources of South Lantau are common possessions and basis of eco-recreation. Mindlessly upgrading the accessibility, particularly vehicular access, will only ruin, very likely irreversibly, these resources and eventually tear down the related business.

52. Accommodation facilities should be carefully designed and controlled. There are quite a few unauthorized camping and caravan sites at the beaches in South Lantau currently. Most of them do not have wastewater treatment systems, that will cause pollution in the surrounding environment and water quality. Such unauthorized facilities should be proscribed, and not for the fulfilment of the proposed accommodation facilities in the Proposal.

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

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Co-signatories (in alphabetic order):
Association for Geoconservation, Hong Kong
Designing Hong Kong
Green Power
Greeners Action
Greenpeace
Hong Kong Bovid Conservation Association
Hong Kong Outdoors
The Conservancy Association
The Green Earth
The Hong Kong Bird Watching Society