Civil Engineering and Development Department and Planning Department
12/F, Tower 2, Grand Central Plaza
138 Shatin Rural Committee Road Shatin, N.T. HongKong
(E-mail: info@nm-ntnorth.hk)
Green Power would like to draw your kind attention to our concerns about the above-captioned proposed development.
General Comments about Land Uses
1. The proposed extent of New Territories North New Town (NTNNT) is largely disturbed by human activities such as established villages, scattered low-density residential areas and open storages. However, it also retains large area of good quality and well irrigated farmlands. Further developments should aim at improving environmental quality, regulating incompatible land uses, increasing land-use efficiency and establishing a novel green city model for Hong Kong with urban-rural harmony and integration and wise use of farmlands.
2. Comprehensive integrated land uses should be in place in the proposed NTNNT to establish a community which is as self-sustained as possible, in order not to compete the social, transport and community resources of the neighbouring communities, namely Sheung Shui and Fanling town.
3. As a New Development Area, however, the proposal ignores the opportunities to cope with localised challenges towards urbanisation including
(a) strengthening the role of existing villages in the context of “urban-rural integration” in the process of urbanisation,
(b) protection of ecology and habitat connection between country parks/natural slopes, river corridors and blue green infrastructures,
(c) wise use of good quality farmlands and irrigation systems to relieve adverse impacts of urbanisation on environmental and living quality,
(d) adaptation to climate change.
Transportation
4. To support the development of proposed NTNNT, the Hong Kong Major Transport Infrastructure Development Blueprint(2023) has recommended two railways, i.e. the Northern Link Eastern Extension and the Northeast New Territories Line, and the Northern Metropolis Highway in boundary of proposed NTNNT.
5. In reference to previous analogous cases such as West Rail Line (currently Tuen Ma Line) and Route 3 Highway in Kam Tin area, the at-grade or viaduct alignments destroyed and fragmented the farmlands, wetlands, and other habitats that significantly degraded the ecological value of Kam Tin area irreversibly.
6. Previous access and paths between many villages in Kam Tin were also cut and realigned due to West Rail Line and Route 3 Highway that caused segregation of rural communities. Such segregation not only disintegrated the social unity and disconnected the social activities of these areas, but also generated inconvenience in short-distant travel. This contradicts the Key Planning and Urban Design Concepts of “Urban-Rural Integration” if recurred in proposed NTNNT.
7. On the other hand, road access can bring about disastrous and irreversible damages to the environment with vandalism, incompatible developments and pollution. In view of its significant environmental impacts, more in-depth transport planning should be included in further studies with due consideration of ecology, pollution, community segregation and habitat fragmentation.
Urban Heat Island Effect
8. During 2021 to 2024, Ta Kwu Leng(TKL), located at the centre of the proposed NTNNT, recorded higher mean daily maximum temperature than the Hong Kong Observatory (HKO), located in urban Kowloon, for almost all months. Even Worse, TKL recorded 42% to 78% more “very hot days (daily maximum temperature≥33°C)” than the (Table 1).
9. Located in the inland plain covering 1420 ha which is more than double of Yau Tsim Mong District area (about 700 ha), proposed NTNNT will create prominent urban heat island effect (UHIE) upon development. The living quality and health issue of NTNNT residents are of grave concern in view of frequent past records of extraordinary high ambient temperature. High energy consumption is required for indoor air conditioning and scorching street environment deters green mobilty modes such as walking and cycling that act contrarily to the Key Planning and Urban Design Concept of “reducing energy consumption” and “facilitating green mobility”.
10. Even worse, extreme heat will impose extra health risk to the vulnerable groups including elderlies, chronic diseases patients and the underprivileges. Such public health risk will lead to substantial demand on medical services and resources, and associated financial implication.
11. Study and computer simulation of meteorology for proposed NTNNT landuse plan should be conducted. The efficiency of district breezeways to reduce UHIE should be scientifically assessed. Owing to the inland location and high-rise buildings, breezeway may not be effective throughout the whole proposed NTNNT area. Measures to relieve UHIE should be incorporated in the major infrastructures, such as roads, and land leases for developments.
12. Also, direct exposure of the public to extremely high temperatures should be reduced, for example, with provision of extensive well-connected shaded pedestrian environment and elimination of heat sources such as exhaust gas from the vehicles and air-conditioners.
Water Quality and Hydrology
13. Being an engulfed water body, Deep Bay is limited in its self-purification power and has already been overloaded with pollution. Since the proposed NTNNT is within the watershed of Shenzhen River which feeds into Deep Bay, the proposed landuses should not cause substantial changes in hydrology (such as the permeability of catchment) and water quality of Shenzhen River to comply with the “zero discharge policy” for Deep Bay and protect the ecology of Ramsar Site in Deep Bay.
14. The physical settings and hydrology of natural rivers/streams should be preserved together with improvement of river water quality. Therefore, the urban surface runoff and non-point source pollution should not be discharged to natural river/stream courses.
15. Establishing a Sustainable Drainage System should be seriously considered which is multi-functional to regulate flooding, collect rainwater for non-potable uses, moderate city’s microclimate and relieve UHIE. On a natural flood plain, the NTNNT should maintain high proportion of permeability by keeping soil surface and vegetation.
16. The purposes of green spine, i.e. Dongjiang Water Greenway and Central River Valley, emphasize on landscaping and green tourism. Negligence of the latter as part of a natural flood plain in landuse and transport planning will cause unnecessary risks.
17. No river channels should be decked because decking of river/stream channels escalates flooding risk in view of increased surface run-off as a result of reduced permeability of proposed NTNNT and altered local precipitation pattern under climate change.
18. Residential buildings, roads should locate further distant from the major river courses to lower the risk of loss of life and property due to flooding. Also, this arrangement can lower the contamination of river water by refuse and polluted surface run-off.
Ecology
19. Proposed developments will lead to massive, irreversible and long-term adverse environmental and ecological impacts on natural rivers, farmlands, wetlands and other habitats in the Northern New Territories.
20. Natural habitats of well-known ecological importance such as the fung shui woods and freshwater marshes are existed in the proposed NTNNT which ecological values should not be underestimated. Green Power has recorded 22 odonate species in Heung Yuen Wai in 2023. Comprehensive literature reviews and ecological surveys should be conducted in order to identify all the historical and existing ecologically sensitive sites within the proposed NTNNT and its periphery. The ecological impacts induced by the proposed development should be fully assessed, avoided and mitigated by effective measures.
21. Although Lin Ma Hang Stream SSSI is not within the boundary of proposed NTNNT, development pressure regarding change of landuse in its watershed and water pollution (point source and non-point source) will be anticipated. Therefore, preservation of Lin Ma Hang Stream should be enhanced through up-zoning its river banks from “Green Belt” to “SSSI”.
22. There are plenty of good quality farmlands and green belts in the proposed NTNNT. These valuable green resources can relieve UHIE, support biodiversity and promote urban-rural harmony and integration. The irrigation systems which may extend beyond the farmlands and reach river courses, which are usually connected to irrigation ditches. These irrigation system should be preserved for operation of farmlands and supporting blue-green landscaping. Therefore, surveys to locate and identify the present irrigation system should be conducted to supplement information and data for continuity of farming practice and design of blue-green landscape.
23. No new roads, whatever permanent or temporary, should be constructed to encroach fung shui woods, natural streams, SSSIs and other valueable habitats to avoid any environmental and ecological impacts.
24. Blue-green infrastructure and “Nature Garden” should NOT be justified as a conservation measure to encroach any identified or potential important aquatic and riparian habitats.
25. Native tree/shrub species are preferred as far as possible for greening, ecological compensation or enhancement. Tree felling and transplantation should be avoided as far as possible.
26. A strip of “Industries” is zoned between Robin’s Nest Country Park and eastern part of NTNNT which is neither compatible nor buffering the natural hillsides of Robin’s Nest Country Park.
Brownfield Proliferation
27. Large area of land in the proposed NTNNT is currently occupied by brownfield operations. The proposed development will likely trigger the spillage of brownfields to the nearby rural areas and countryside, therefore a proper reallocation and/or compensation plan for the existing brownfield operations should be formulated in the early stage before the construction phase to prevent an expansion of unfavorable and uncontrollable land uses at the periphery of the proposed NTNNT.
Eco-vandalism
28. Fly-tipping and illegal dumping should be strictly prohibited during the construction phase because the areas around the proposed NTNNT are notorious for the destruction of ecologically sensitive sites by massive dumping of wastes and debris, especially C&D waste. Regrettably, restoration of filled farmlands, fishponds, or wetlands are non-enforceable, inefficient, or impractical in most cases.
29. Effective and deterring measures to confine the travelling routes of dump trucks and similar machineries related to the proposed development should be utilized, e.g. “no-go” areas, real-time GPS devices on the trucks, instantaneous alarm alert for the trucks deviated from the designated routes, should be seriously considered. Implementation of such measures and associated penalties shall be included in the contract terms to effectively control the irregular activities of relevant contractors.
Carbon-Neutral
30. District-wide proposal to reduce energy consumption and wastes should be included in the formulation of landuse and transport plans. Energy efficiency of buildings, renewable energy and public transportation should be promoted to lower carbon footprint. Sufficient land space should be allocated for waste collection, transportation, recycling to support and sustain waste reduction.
Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2000, Email: info@greenpower.org.hk).
Green Power would like to draw your kind attention to our concerns about the above-captioned proposed development.
General Comments about Land Uses
1. The proposed extent of New Territories North New Town (NTNNT) is largely disturbed by human activities such as established villages, scattered low-density residential areas and open storages. However, it also retains large area of good quality and well irrigated farmlands. Further developments should aim at improving environmental quality, regulating incompatible land uses, increasing land-use efficiency and establishing a novel green city model for Hong Kong with urban-rural harmony and integration and wise use of farmlands.
2. Comprehensive integrated land uses should be in place in the proposed NTNNT to establish a community which is as self-sustained as possible, in order not to compete the social, transport and community resources of the neighbouring communities, namely Sheung Shui and Fanling town.
3. As a New Development Area, however, the proposal ignores the opportunities to cope with localised challenges towards urbanisation including
(a) strengthening the role of existing villages in the context of “urban-rural integration” in the process of urbanisation,
(b) protection of ecology and habitat connection between country parks/natural slopes, river corridors and blue green infrastructures,
(c) wise use of good quality farmlands and irrigation systems to relieve adverse impacts of urbanisation on environmental and living quality,
(d) adaptation to climate change.
Transportation
4. To support the development of proposed NTNNT, the Hong Kong Major Transport Infrastructure Development Blueprint(2023) has recommended two railways, i.e. the Northern Link Eastern Extension and the Northeast New Territories Line, and the Northern Metropolis Highway in boundary of proposed NTNNT.
5. In reference to previous analogous cases such as West Rail Line (currently Tuen Ma Line) and Route 3 Highway in Kam Tin area, the at-grade or viaduct alignments destroyed and fragmented the farmlands, wetlands, and other habitats that significantly degraded the ecological value of Kam Tin area irreversibly.
6. Previous access and paths between many villages in Kam Tin were also cut and realigned due to West Rail Line and Route 3 Highway that caused segregation of rural communities. Such segregation not only disintegrated the social unity and disconnected the social activities of these areas, but also generated inconvenience in short-distant travel. This contradicts the Key Planning and Urban Design Concepts of “Urban-Rural Integration” if recurred in proposed NTNNT.
7. On the other hand, road access can bring about disastrous and irreversible damages to the environment with vandalism, incompatible developments and pollution. In view of its significant environmental impacts, more in-depth transport planning should be included in further studies with due consideration of ecology, pollution, community segregation and habitat fragmentation.
Urban Heat Island Effect
8. During 2021 to 2024, Ta Kwu Leng(TKL), located at the centre of the proposed NTNNT, recorded higher mean daily maximum temperature than the Hong Kong Observatory (HKO), located in urban Kowloon, for almost all months. Even Worse, TKL recorded 42% to 78% more “very hot days (daily maximum temperature≥33°C)” than the (Table 1).
9. Located in the inland plain covering 1420 ha which is more than double of Yau Tsim Mong District area (about 700 ha), proposed NTNNT will create prominent urban heat island effect (UHIE) upon development. The living quality and health issue of NTNNT residents are of grave concern in view of frequent past records of extraordinary high ambient temperature. High energy consumption is required for indoor air conditioning and scorching street environment deters green mobilty modes such as walking and cycling that act contrarily to the Key Planning and Urban Design Concept of “reducing energy consumption” and “facilitating green mobility”.
10. Even worse, extreme heat will impose extra health risk to the vulnerable groups including elderlies, chronic diseases patients and the underprivileges. Such public health risk will lead to substantial demand on medical services and resources, and associated financial implication.
11. Study and computer simulation of meteorology for proposed NTNNT landuse plan should be conducted. The efficiency of district breezeways to reduce UHIE should be scientifically assessed. Owing to the inland location and high-rise buildings, breezeway may not be effective throughout the whole proposed NTNNT area. Measures to relieve UHIE should be incorporated in the major infrastructures, such as roads, and land leases for developments.
12. Also, direct exposure of the public to extremely high temperatures should be reduced, for example, with provision of extensive well-connected shaded pedestrian environment and elimination of heat sources such as exhaust gas from the vehicles and air-conditioners.
Water Quality and Hydrology
13. Being an engulfed water body, Deep Bay is limited in its self-purification power and has already been overloaded with pollution. Since the proposed NTNNT is within the watershed of Shenzhen River which feeds into Deep Bay, the proposed landuses should not cause substantial changes in hydrology (such as the permeability of catchment) and water quality of Shenzhen River to comply with the “zero discharge policy” for Deep Bay and protect the ecology of Ramsar Site in Deep Bay.
14. The physical settings and hydrology of natural rivers/streams should be preserved together with improvement of river water quality. Therefore, the urban surface runoff and non-point source pollution should not be discharged to natural river/stream courses.
15. Establishing a Sustainable Drainage System should be seriously considered which is multi-functional to regulate flooding, collect rainwater for non-potable uses, moderate city’s microclimate and relieve UHIE. On a natural flood plain, the NTNNT should maintain high proportion of permeability by keeping soil surface and vegetation.
16. The purposes of green spine, i.e. Dongjiang Water Greenway and Central River Valley, emphasize on landscaping and green tourism. Negligence of the latter as part of a natural flood plain in landuse and transport planning will cause unnecessary risks.
17. No river channels should be decked because decking of river/stream channels escalates flooding risk in view of increased surface run-off as a result of reduced permeability of proposed NTNNT and altered local precipitation pattern under climate change.
18. Residential buildings, roads should locate further distant from the major river courses to lower the risk of loss of life and property due to flooding. Also, this arrangement can lower the contamination of river water by refuse and polluted surface run-off.
Ecology
19. Proposed developments will lead to massive, irreversible and long-term adverse environmental and ecological impacts on natural rivers, farmlands, wetlands and other habitats in the Northern New Territories.
20. Natural habitats of well-known ecological importance such as the fung shui woods and freshwater marshes are existed in the proposed NTNNT which ecological values should not be underestimated. Green Power has recorded 22 odonate species in Heung Yuen Wai in 2023. Comprehensive literature reviews and ecological surveys should be conducted in order to identify all the historical and existing ecologically sensitive sites within the proposed NTNNT and its periphery. The ecological impacts induced by the proposed development should be fully assessed, avoided and mitigated by effective measures.
21. Although Lin Ma Hang Stream SSSI is not within the boundary of proposed NTNNT, development pressure regarding change of landuse in its watershed and water pollution (point source and non-point source) will be anticipated. Therefore, preservation of Lin Ma Hang Stream should be enhanced through up-zoning its river banks from “Green Belt” to “SSSI”.
22. There are plenty of good quality farmlands and green belts in the proposed NTNNT. These valuable green resources can relieve UHIE, support biodiversity and promote urban-rural harmony and integration. The irrigation systems which may extend beyond the farmlands and reach river courses, which are usually connected to irrigation ditches. These irrigation system should be preserved for operation of farmlands and supporting blue-green landscaping. Therefore, surveys to locate and identify the present irrigation system should be conducted to supplement information and data for continuity of farming practice and design of blue-green landscape.
23. No new roads, whatever permanent or temporary, should be constructed to encroach fung shui woods, natural streams, SSSIs and other valueable habitats to avoid any environmental and ecological impacts.
24. Blue-green infrastructure and “Nature Garden” should NOT be justified as a conservation measure to encroach any identified or potential important aquatic and riparian habitats.
25. Native tree/shrub species are preferred as far as possible for greening, ecological compensation or enhancement. Tree felling and transplantation should be avoided as far as possible.
26. A strip of “Industries” is zoned between Robin’s Nest Country Park and eastern part of NTNNT which is neither compatible nor buffering the natural hillsides of Robin’s Nest Country Park.
Brownfield Proliferation
27. Large area of land in the proposed NTNNT is currently occupied by brownfield operations. The proposed development will likely trigger the spillage of brownfields to the nearby rural areas and countryside, therefore a proper reallocation and/or compensation plan for the existing brownfield operations should be formulated in the early stage before the construction phase to prevent an expansion of unfavorable and uncontrollable land uses at the periphery of the proposed NTNNT.
Eco-vandalism
28. Fly-tipping and illegal dumping should be strictly prohibited during the construction phase because the areas around the proposed NTNNT are notorious for the destruction of ecologically sensitive sites by massive dumping of wastes and debris, especially C&D waste. Regrettably, restoration of filled farmlands, fishponds, or wetlands are non-enforceable, inefficient, or impractical in most cases.
29. Effective and deterring measures to confine the travelling routes of dump trucks and similar machineries related to the proposed development should be utilized, e.g. “no-go” areas, real-time GPS devices on the trucks, instantaneous alarm alert for the trucks deviated from the designated routes, should be seriously considered. Implementation of such measures and associated penalties shall be included in the contract terms to effectively control the irregular activities of relevant contractors.
Carbon-Neutral
30. District-wide proposal to reduce energy consumption and wastes should be included in the formulation of landuse and transport plans. Energy efficiency of buildings, renewable energy and public transportation should be promoted to lower carbon footprint. Sufficient land space should be allocated for waste collection, transportation, recycling to support and sustain waste reduction.
Thank you very much for your kind attention. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2000, Email: info@greenpower.org.hk).
Yours faithfully,
CHENG Luk Ki
Director, GREEN POWER
Yours faithfully,
CHENG Luk Ki
Director, GREEN POWER