政策倡議及咨詢

BY EMAIL ONLY
27
 
June
 
2025

Mr. CHAN Jick-chi, Jack
The Ombudsman
30/F, China Merchants Tower,
Shun Tak Centre,
168–200 Connaught Road,
Central, Hong Kong

(Fax: 2882 8149, Email: di483@ombudsman.hk)

cc.
Dear Mr. Chan,
Green Power’s Response to Ombudsman Probe Regarding Enhanced Management of Countryside Ancillary Tourist Facilities to Pursue “Tourism is Everywhere”
Green Power’s Response to Ombudsman Probe Regarding Enhanced Management of Countryside Ancillary Tourist Facilities to Pursue “Tourism is Everywhere”

1. Green Power, a local charitable environmental NGO, organizes outdoor guided tours and hiking events for the public and students, and citizen scientist programmes in countryside in the territory for decades. We also have also published many guide books and magazines recommending hiking routes and introducing natural scenery and flora and fauna in our wilderness.

2. As an experienced user and introducer of Hong Kong’s countryside, we would like to respond to the Ombudsman’s solicitation of public views towards HKSAR Government’s management of countryside ancillary tourist facilities to align with its efforts to develop green tourism and the pursuit of the ideas of “tourism is everywhere” and “sightseeing all over Hong Kong”.

3. We concur that “proper management of countryside ancillary tourist facilities not only helps protect the safety of hikers and visitors but also enhances the outdoor experience for members of the public and tourists.”  

4. In order to establish required goals of investigation and pertinent recommendations, the activities, venues, and administration and management authorities involved in the investigation should be specified.

Explicit Scopes of Investigation  

5. The intended investigation is targeted at activity “green tourism” and venue “countryside”. We observe that the term “green tourism” may imply as or interchangeable with “sustainable tourism”, “responsible tourism” and “ecotourism” in the process of tourist promotion and relevant discussion. “Countryside” is an ambiguous term to categorized wild places with minimal human activity and rural areas or settlements mainly with natural or nonurban settings. Practically, it may include Country Parks (CPs), Marine Parks (MPs), Geo Parks (GPs), Nature Reserves (NRs), Marine Reserves (MRs), Site of Special Scientific Interests (SSSIs), natural habitats (i.e. coastlines, beaches, mudflats, mangroves, fung shui woods, etc.), hiking trails, villages, farms, reservoirs, etc.

6. According to the UN Tourism's definition(1), ecotourism refers to forms of tourism which have the following characteristics:  

(a) All nature-based forms of tourism in which the main motivation of the tourists is the observation and appreciation of nature as well as the traditional cultures prevailing in natural areas.

(b) It contains educational and interpretation features.

(c) It is generally, but not exclusively organised by specialised tour operators for small groups. Service provider partners at the destinations tend to be small, locally owned businesses.

(d) It minimises negative impacts upon the natural and socio-cultural environment.

(e) It supports the maintenance of natural areas which are used as ecotourism attractions by:

(i) Generating economic benefits for host communities, organisations and authorities managing natural areas with conservation purposes;

(ii) Providing alternative employment and income opportunities for local communities;

(iii) Increasing awareness towards the conservation of natural and cultural assets, both among locals and tourists.

7. The United Nations Environment Programme and World Trade Organization have defined “Sustainable Tourism” as “tourism that takes full account of its current and future economic, social and environmental impacts, addressing the needs of visitors, the industry, the environment, and host communities.”(2)

8. Thus, “Sustainable Tourism” should:  

(a) Make optimal use of environmental resources that constitute a key element in tourism development, maintaining essential ecological processes and helping to conserve natural heritage and biodiversity.

(b) Respect the socio-cultural authenticity of host communities, conserve their built and living cultural heritage and traditional values, and contribute to inter-cultural understanding and tolerance.

(c) Ensure viable, long-term economic operations, providing socio-economic benefits to all stakeholders that are fairly distributed, including stable employment and income-earning opportunities and social services to host communities, and contributing to poverty alleviation.

9. “Responsible Tourism” was defined as “tourism that promotes responsibility to the environment through its sustainable use; responsibility to involve local communities in the tourism industry, responsibility for the safety and security of visitors and responsible government, employees, employers, unions and local communities.”(3)

10. Although “green tourism” is not a commonly adopted term by international authoritative organisations, it obviously refers to the alternative tourist experience in natural destinations. More specifically, the Administration has considered “green tourism” equivalent to “ecotourism”.(4)

11. Therefore, in view of the intention of the captioned investigation, the definition and principles of “ecotourism” should be adopted as it is obviously focused at nature-based forms of tourism in rural or natural areas. Whereas, the definitions of “sustainable tourism” and “responsible tourism” are similar but do not necessarily aim at destinations of natural or rural settings.

12. Although the cases triggered the captioned investigation were mainly in the boundary of CPs, these incidents involved different authorities regarding various aspects of facility operation and information dissemination including hiking trails, toilets, rubbish bins, emergency distress facilities, drinking water stations, and signage. The comprehensive understanding of these incidents should include all governmental authorities, public services providers and venue managers that operate, maintain and serve the related facilities and users in the investigation. Bias or prejudgment may render not only the investigation ineffective but also the problems unresolved.

13. Therefore, different governmental authorities, public services providers and venue managers with relevant statutory enforcement power, responsibility and jurisdiction exercising in “countryside” in the territory should be thoroughly identified and participated in the investigation.

14. Also, the countryside venues under the captioned investigation should include but no limited to Country Parks (CPs), Marine Parks (MPs), Geo Parks (GPs), Nature Reserves (NRs), Marine Reserves (MRs), Site of Special Scientific Interests (SSSIs), natural habitats (i.e. coastlines, beaches, mudflats, mangroves, fung shui woods, etc.), hiking trails, villages, farms, reservoirs. These countryside venues are accessible for local or foreign visitors and hence visitors are vulnerable to encountering perturbed experience.

Landuse Planning

15. When assessing the adequacy of facility provision in countryside, planned landuses of the investigated venues must be taken into account that have been assigned according to functions, constraints, carrying capacity and landscape characteristics.

16. In the context of tourism, many tourist hotspots are not zoned for tourism. Instead they may be zoned for “Country Park”, “SSSI”, “Conservation Area”, “Agriculture”, “Village Development”,etc. in landuse plans such as Outline Zoning Plans (OZPs).

17. Also, some venues are listed for particular statutory functions. For example, “Water Gathering Grounds (WGGs)” and “Reservoirs” are listed under Waterworks Ordinance (Cap. 102) for collection of potable water. Most of the WGGs also fall within Country Parks and are protected by the Country Parks Ordinance (Cap. 208).

18. Restricted vehicular access to WGGs and CPs is necessary to protect the WGGs against air pollution and noise impacts to ecology and biodiversity, and illegal dumping of wastes. These polluting activities not only damage the ecological and water resources but also ruin the scenic tourist resources.

19. Owing to the fragileness, sensitiveness and uniqueness of certain countryside venues, most of them are zoned for low-impact activities and minimal developments. Thus, these venues are suitable for passive recreation such as hiking or outdoor education only, and not able to cater for mass tourism or massive visitor flow without proper control measures.

Expectation Management of Visitors

20. Some conventional tourist facilities, such as shopping malls, restaurants, etc., are situated in countryside (e.g. the Peak), and hence ready to receive large number of visitors with well connected transportation. However, most popular countryside spots famous for its unique and attractive scenery (e.g. Lion Rock), which are perceived as tourist spots for ordinary visitors, lack proper conventional tourist facilities such as catering services, grocery/souvenir shops, toilets, etc., and convenient vehicular access.

21. Owing to difference in social, cultural backgrounds and personal interpretation, the current provision of logistics and facilities of countryside may mismatch visitors’ expectation and may lead to safety issues and perturbing experiences.

22. To facilitate the high visitor volume in certain countryside venues, development of tourist facilities should be cautiously assessed. First, the persistence of popularity to visit these venues should be rationally forecast. Investment of tourist supporting and transportation facilities for ad hoc or temporary tourist hotspots in ecologically sensitive countryside will give rise to management and financial burden for a long run in addition to unnecessary loss or disturbance to the natural assets.

23. In the context of whole society, development of tourist facilities may not be cost-efficient, Therefore, dissemination of updated and relevant information to visitors about the popular countryside venues may be more effective and efficient to avoid perturbed experience and accidents. These information should include schedules of public transport tools, availability of facilities, topography, harshness and expected completion time of trails, weather forecast, safety precaution, etc.

24. On the other hand, establishment of any facilities should not jeopardize the “ecosystem services” of the countryside. The facilities should not discharge wastewater and sewage polluting natural rivers/streams and WGGs. Crowd control should be maintained in habitats for species of concern. In fact, increased visitor number in some countryside trails has already significantly impacted some rare plant species. Some slope maintenance works in countryside also cause loss of rare plant population, as natural slopes are their important habitats.

25. Visitors should also be notified regarding some measures and conducts in countryside which may be contrary to their usual expectation, for example, "Take Your Litter Home" in CPs, no feeding of wild animals and fish, no collection and poaching of wild plants and animals, no swimming in reservoirs, no damage and disturbance to villagers’ crops and daily life, etc.

Priorities for “Green Tourism”

26. “Green tourism”, which the Administration treats it as well-known “ecotourism”, not only locates the tourist activities in a countryside scene, but also interacts with the local ecological, environmental, cultural entities resulting in benefits to conservation of ecosystem, human use of natural resources, livelihood of local community and conservation awareness of the tourists.

27. Therefore, any developments and measures in the name of “green tourism’ should aim at conserving the natural and cultural assets and take into account of the carrying capacity of the countryside venues.

28. “Precautionary principle” should be followed when no scientific or reasonably reliable assessment of carrying capacity is available for any development in countryside. The principle states that “where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”(5)  

29. Education for tourists, local community and tourist sector to conserve natural and cultural resources should accord a high priority when planning to establish or upgrade “green tourism” spots.

30. Effective control and surveillance measures should be in place to monitor the quality of tourist facilities operation, conduct of service providers, education and tourist services, and environmental and ecological parameters.

31. In view that Hong Kong possesses many world-class natural landscapes, they are precious “ecotourism” resources if “green tourism” can be appropriately promoted with policy, administrative and financial support. Policy and management framework should be formulated to ensure the perpetuation of “ecotourism” resources and consequent benefits to the whole society.

Thank you very much for your kind attention.

1. Green Power, a local charitable environmental NGO, organizes outdoor guided tours and hiking events for the public and students, and citizen scientist programmes in countryside in the territory for decades. We also have also published many guide books and magazines recommending hiking routes and introducing natural scenery and flora and fauna in our wilderness.

2. As an experienced user and introducer of Hong Kong’s countryside, we would like to respond to the Ombudsman’s solicitation of public views towards HKSAR Government’s management of countryside ancillary tourist facilities to align with its efforts to develop green tourism and the pursuit of the ideas of “tourism is everywhere” and “sightseeing all over Hong Kong”.

3. We concur that “proper management of countryside ancillary tourist facilities not only helps protect the safety of hikers and visitors but also enhances the outdoor experience for members of the public and tourists.”  

4. In order to establish required goals of investigation and pertinent recommendations, the activities, venues, and administration and management authorities involved in the investigation should be specified.

Explicit Scopes of Investigation  

5. The intended investigation is targeted at activity “green tourism” and venue “countryside”. We observe that the term “green tourism” may imply as or interchangeable with “sustainable tourism”, “responsible tourism” and “ecotourism” in the process of tourist promotion and relevant discussion. “Countryside” is an ambiguous term to categorized wild places with minimal human activity and rural areas or settlements mainly with natural or nonurban settings. Practically, it may include Country Parks (CPs), Marine Parks (MPs), Geo Parks (GPs), Nature Reserves (NRs), Marine Reserves (MRs), Site of Special Scientific Interests (SSSIs), natural habitats (i.e. coastlines, beaches, mudflats, mangroves, fung shui woods, etc.), hiking trails, villages, farms, reservoirs, etc.

6. According to the UN Tourism's definition(1), ecotourism refers to forms of tourism which have the following characteristics:  

(a) All nature-based forms of tourism in which the main motivation of the tourists is the observation and appreciation of nature as well as the traditional cultures prevailing in natural areas.

(b) It contains educational and interpretation features.

(c) It is generally, but not exclusively organised by specialised tour operators for small groups. Service provider partners at the destinations tend to be small, locally owned businesses.

(d) It minimises negative impacts upon the natural and socio-cultural environment.

(e) It supports the maintenance of natural areas which are used as ecotourism attractions by:

(i) Generating economic benefits for host communities, organisations and authorities managing natural areas with conservation purposes;

(ii) Providing alternative employment and income opportunities for local communities;

(iii) Increasing awareness towards the conservation of natural and cultural assets, both among locals and tourists.

7. The United Nations Environment Programme and World Trade Organization have defined “Sustainable Tourism” as “tourism that takes full account of its current and future economic, social and environmental impacts, addressing the needs of visitors, the industry, the environment, and host communities.”(2)

8. Thus, “Sustainable Tourism” should:  

(a) Make optimal use of environmental resources that constitute a key element in tourism development, maintaining essential ecological processes and helping to conserve natural heritage and biodiversity.

(b) Respect the socio-cultural authenticity of host communities, conserve their built and living cultural heritage and traditional values, and contribute to inter-cultural understanding and tolerance.

(c) Ensure viable, long-term economic operations, providing socio-economic benefits to all stakeholders that are fairly distributed, including stable employment and income-earning opportunities and social services to host communities, and contributing to poverty alleviation.

9. “Responsible Tourism” was defined as “tourism that promotes responsibility to the environment through its sustainable use; responsibility to involve local communities in the tourism industry, responsibility for the safety and security of visitors and responsible government, employees, employers, unions and local communities.”(3)

10. Although “green tourism” is not a commonly adopted term by international authoritative organisations, it obviously refers to the alternative tourist experience in natural destinations. More specifically, the Administration has considered “green tourism” equivalent to “ecotourism”.(4)

11. Therefore, in view of the intention of the captioned investigation, the definition and principles of “ecotourism” should be adopted as it is obviously focused at nature-based forms of tourism in rural or natural areas. Whereas, the definitions of “sustainable tourism” and “responsible tourism” are similar but do not necessarily aim at destinations of natural or rural settings.

12. Although the cases triggered the captioned investigation were mainly in the boundary of CPs, these incidents involved different authorities regarding various aspects of facility operation and information dissemination including hiking trails, toilets, rubbish bins, emergency distress facilities, drinking water stations, and signage. The comprehensive understanding of these incidents should include all governmental authorities, public services providers and venue managers that operate, maintain and serve the related facilities and users in the investigation. Bias or prejudgment may render not only the investigation ineffective but also the problems unresolved.

13. Therefore, different governmental authorities, public services providers and venue managers with relevant statutory enforcement power, responsibility and jurisdiction exercising in “countryside” in the territory should be thoroughly identified and participated in the investigation.

14. Also, the countryside venues under the captioned investigation should include but no limited to Country Parks (CPs), Marine Parks (MPs), Geo Parks (GPs), Nature Reserves (NRs), Marine Reserves (MRs), Site of Special Scientific Interests (SSSIs), natural habitats (i.e. coastlines, beaches, mudflats, mangroves, fung shui woods, etc.), hiking trails, villages, farms, reservoirs. These countryside venues are accessible for local or foreign visitors and hence visitors are vulnerable to encountering perturbed experience.

Landuse Planning

15. When assessing the adequacy of facility provision in countryside, planned landuses of the investigated venues must be taken into account that have been assigned according to functions, constraints, carrying capacity and landscape characteristics.

16. In the context of tourism, many tourist hotspots are not zoned for tourism. Instead they may be zoned for “Country Park”, “SSSI”, “Conservation Area”, “Agriculture”, “Village Development”,etc. in landuse plans such as Outline Zoning Plans (OZPs).

17. Also, some venues are listed for particular statutory functions. For example, “Water Gathering Grounds (WGGs)” and “Reservoirs” are listed under Waterworks Ordinance (Cap. 102) for collection of potable water. Most of the WGGs also fall within Country Parks and are protected by the Country Parks Ordinance (Cap. 208).

18. Restricted vehicular access to WGGs and CPs is necessary to protect the WGGs against air pollution and noise impacts to ecology and biodiversity, and illegal dumping of wastes. These polluting activities not only damage the ecological and water resources but also ruin the scenic tourist resources.

19. Owing to the fragileness, sensitiveness and uniqueness of certain countryside venues, most of them are zoned for low-impact activities and minimal developments. Thus, these venues are suitable for passive recreation such as hiking or outdoor education only, and not able to cater for mass tourism or massive visitor flow without proper control measures.

Expectation Management of Visitors

20. Some conventional tourist facilities, such as shopping malls, restaurants, etc., are situated in countryside (e.g. the Peak), and hence ready to receive large number of visitors with well connected transportation. However, most popular countryside spots famous for its unique and attractive scenery (e.g. Lion Rock), which are perceived as tourist spots for ordinary visitors, lack proper conventional tourist facilities such as catering services, grocery/souvenir shops, toilets, etc., and convenient vehicular access.

21. Owing to difference in social, cultural backgrounds and personal interpretation, the current provision of logistics and facilities of countryside may mismatch visitors’ expectation and may lead to safety issues and perturbing experiences.

22. To facilitate the high visitor volume in certain countryside venues, development of tourist facilities should be cautiously assessed. First, the persistence of popularity to visit these venues should be rationally forecast. Investment of tourist supporting and transportation facilities for ad hoc or temporary tourist hotspots in ecologically sensitive countryside will give rise to management and financial burden for a long run in addition to unnecessary loss or disturbance to the natural assets.

23. In the context of whole society, development of tourist facilities may not be cost-efficient, Therefore, dissemination of updated and relevant information to visitors about the popular countryside venues may be more effective and efficient to avoid perturbed experience and accidents. These information should include schedules of public transport tools, availability of facilities, topography, harshness and expected completion time of trails, weather forecast, safety precaution, etc.

24. On the other hand, establishment of any facilities should not jeopardize the “ecosystem services” of the countryside. The facilities should not discharge wastewater and sewage polluting natural rivers/streams and WGGs. Crowd control should be maintained in habitats for species of concern. In fact, increased visitor number in some countryside trails has already significantly impacted some rare plant species. Some slope maintenance works in countryside also cause loss of rare plant population, as natural slopes are their important habitats.

25. Visitors should also be notified regarding some measures and conducts in countryside which may be contrary to their usual expectation, for example, "Take Your Litter Home" in CPs, no feeding of wild animals and fish, no collection and poaching of wild plants and animals, no swimming in reservoirs, no damage and disturbance to villagers’ crops and daily life, etc.

Priorities for “Green Tourism”

26. “Green tourism”, which the Administration treats it as well-known “ecotourism”, not only locates the tourist activities in a countryside scene, but also interacts with the local ecological, environmental, cultural entities resulting in benefits to conservation of ecosystem, human use of natural resources, livelihood of local community and conservation awareness of the tourists.

27. Therefore, any developments and measures in the name of “green tourism’ should aim at conserving the natural and cultural assets and take into account of the carrying capacity of the countryside venues.

28. “Precautionary principle” should be followed when no scientific or reasonably reliable assessment of carrying capacity is available for any development in countryside. The principle states that “where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”(5)  

29. Education for tourists, local community and tourist sector to conserve natural and cultural resources should accord a high priority when planning to establish or upgrade “green tourism” spots.

30. Effective control and surveillance measures should be in place to monitor the quality of tourist facilities operation, conduct of service providers, education and tourist services, and environmental and ecological parameters.

31. In view that Hong Kong possesses many world-class natural landscapes, they are precious “ecotourism” resources if “green tourism” can be appropriately promoted with policy, administrative and financial support. Policy and management framework should be formulated to ensure the perpetuation of “ecotourism” resources and consequent benefits to the whole society.

Thank you very much for your kind attention.

Yours faithfully,

CHENG Luk Ki
Director, GREEN POWER

Yours faithfully,

CHENG Luk Ki
Director, GREEN POWER

二零二五年
六月
二十七日