Policy Comments & Advocacy

Green Power would like to draw your kind attention to our concerns regarding the above-captioned Project Profile (PP). While the Project aims at supporting the development of the yacht economy and island tourism, we are concerned that the current PP understates or disregards several environmental, ecological, and biodiversity impacts associated with constructing and operating a 150-to-200-berth marina and associated developments in the semi-enclosed inner bay and former quarry area of Sok Kwu Wan, Lamma Island.

Potential Threats to Green Turtles

1. The beach at Sham Wan, Lamma Island is the only site in Hong Kong and one of the few sites in South China Sea at which Green Turtles (Chelonia mydas) nest from time to time. The area has become a Site of Special Scientific Interest (SSSI) since 1999. The beach and the adjacent waters in the inlet of the sea at Sham Wan has been designated as a Restricted Area under the Wild Animals Protection Ordinance (Cap. 170) and the restricted period is 1 April to 31 October every year.

2. Vessel collision and propeller strikes are the major threats to the survival of sea turtles. Although the Project site is situated at central part of Lamma Island while Sham Wan is in the southern side, potential impacts of the Project on Green Turtle should be avoided or minimized by

(a) Vessel speed limitation in near-shore water around Lamma Island,

(b) Strict enforcement of Restricted Area at Sham Wan,

(c) Avoidance of light interference to sea turtles at night,

(d) Effective ban of dumping wastes at sea for all vessels, especially plastic wastes which may be mistaken as edible preys by sea turtles.

Conserving Biodiversity

3. Lamma Island possesses exceptionally rich biodiversity that warrants stringent conservation under the Biodiversity Strategy and Action Plan (BSAP) and the Convention on Biological Diversity (CBD). Surveys conducted (2011-2013) across Lamma have recorded over 110 bird species, including rare winter visitors such as Chinese Sparrowhawk (Accipiter soloensis), Eurasian Woodcock (Scolopax rusticola), Eurasian Hoopoes (Upupa epops), Forest Wagtail (Dendronanthus indicus), Bluethroat (Luscinia svecica), Grey-headed Canary-flycatcher (Culicicapa ceylonensis), Common Starling (Sturnus vulgaris), and Brambling (Fringilla montifringilla). Historical records showed that the quarry area itself supported significant egret populations (183 individuals in 2011 and 142 in 2014) and 24 Black Kites with breeding records.

4. Romer's Tree Frog (Liuixalus romeri), endemic to Hong Kong, naturally occurs on Lamma Island. Lamma also supports over 100 butterfly species, 11 dragonfly species, and 648 vascular plant and flora species, including 151 very rare and 39 rare plant species such as Philippine's Hackberry (Celtis timorensis) and Biond's Hackberry (Celtis biondii).

5. South Lamma—extending from Lo So Shing beach to Sham Wan—has been zoned as a SSSI since 1980 for being habitat for a bird population of unusual species . Furthermore, Lamma Island has long been recognized as a potential Country Park site since 1967.

6. The Project should update potential affected habitats and species. Effective plans to avoid damage, disturbance or fragmentation of affected habitats and vulnerable species should be devised and executed.

7. Indo-Pacific Finless Porpoises (Neophocaena phocaenoides) have been recorded in recent years at the waters to the west of Lamma Island  and they are vulnerable to marine traffic noise. Passive acoustic detectors could be deployed at the project site such that when any marine mammal is detected, the nearby working vessels can make timely responses to stop navigating or limit their speed.

Impacts of Anti-fouling Agents on Fisheries, and Marine Ecology

8. The PP notes that hard and soft coral communities exist in Sok Kwu Wan (Sec. 3.6.3) with low to moderate ecological value. On the other hand, the nearest Sok Kwu Wan Fish Culture Zone (FCZ) is located approximately 45 meters from the Project boundary (Section 3.7.1). Installation works, marine piling, propeller wash, and vessel maneuvers will generate suspended solids and localized sediment resuspension, severely impacting mariculture operations, commercial fisheries spawning grounds and marine ecology. We recommend mandatory silt curtains, strict speed limits, and rigorous water quality monitoring.

9. The operation of 150 to 200 large yachts (10 to 50 meters in length) in the semi-enclosed water body of Sok Kwu Wan presents severe ecotoxicological risks from the leaching and flaking of toxic antifouling paints and biocides. Comprehensive ecotoxicity assessments must be conducted, and in-water hull scraping or cleaning must be strictly prohibited to safeguard local marine life and FCZ operation.

10. More importantly, biocides used in yachts and associated berthing/mooring facilities may not be effectively controlled under existing legislations. However, reared fishes in FCZ are highly vulnerable to various biocides/antifouling agents, especially the fingerlings. We recommend that all materials (including paints, plastic, preserved wood, etc) used in the Project should have undergone ecological toxicity tests, e.g. whole effluent toxicity test (WET) or fish embryo toxicity test, to safeguard the operation of FCZ against any toxins leached from the construction materials.

11. Also, chemicals and fuels must be adequately stored to avoid spillages by faulty operations, bad weather events (e.g. typhoons) or fire incidents. Contingency plans should be devised and approved by relevant authorities.

Waste Management and Prevention of Eco-Vandalism

12. To prevent illegal dumping, fly-tipping, and marine refuse accumulation during construction and operation, effective surveillance measures should be in place (e.g. real-time GPS tracking systems for all work vessels, alongside automated floating refuse collection systems).

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).