The Secretary,
Town Planning Board,
15/F, North Point Government Offices,
333 Java Road, North Point, Hong Kong
(Email: tpbpd@pland.gov.hk)
Green Power is writing to submit our views on the captioned planning application (the Application) for temporary uses at Sham Chung, Tai Po which has been identified as a Priority Site under the New Nature Conservation Policy1. While recognizing the value of promoting tourism and recreational opportunities in rural areas, we have profound concerns regarding the sustainability and potential environmental impacts of the proposed development, particularly on the sensitive rural and natural environment of Sham Chung. We urge the Town Planning Board (TPB) members to look into the significant inadequacies in the Application.
Ecological and Hydrological Sensitivity of Sham Chung
1. Sham Chung (the Area) is located within a recognized rural and ecologically sensitive landscape in the New Territories which is a Priority Site under the New Nature Conservation Policy1. The area is characterized by its natural streams, mangroves, freshwater wetlands, coastal features, woodlands and proximity to Country Park. Various rare wildlife have been recorded in Sham Chung, including Hong Kong Paradise Fish (Macropodus hongkongensis, 香港鬥魚) and Sapphire Flutterer (Rhyothemis triangularis, 三角麗翅蜻). The shortest distance between the Application Site and the Ecologically Important Stream (EIS)2 is only about 110 metre. Any development, even temporary, should take "precautionary principle" for planning, construction, operation and management to avoid degradation of water quality, habitat disturbance, and pollution of the surrounding environment, which aligns with the general planning intention for the Area "to conserve the areas of high ecological significance" (Sec. 8.1, EXPLANATORY STATEMENT, OZP S/NE-SC/3).
Inadequate Assessment and Mitigation for Sewage and Wastewater
2. The Planning Statement (the Statement) asserts that the existing septic tank system, with a volume of approximately 9 cubic meters, is sufficient to cater for a maximum of 50 visitors per night. This assessment appears simplistic and fails to account for all sources of wastewater and environmental risk factors:
o Hydraulic Overloading: Septic tanks for village houses, e.g. exemption houses (mostly three floors, about 64 sq, metre each floor) are of domestic scale usually serve for resident number under 20 persons. The capacity of the septic tank is in doubt for the purpose of the proposed development under peak loading conditions, especially during weekend or holiday periods. Moreover, there is no assessment of the soil's percolation capacity or level of water table that significantly affect hydraulic retention time and treatment efficiency of the septic tank.
o Lack of Contingency and Maintenance Plan: The Application Site relies on a soak-away system. No plan is provided regarding the frequency and method of desludging the septic tank to avoid overflow. Leaked sewage will pose high hygienic risk and pollute neighbouring stream water and wetland habitats. For a commercial operation, a formal and frequent maintenance schedule is essential to prevent system failure. The Statement lacks an enforceable plan to ensure this maintenance will be rigorously carried out for the duration of the temporary use.
o Unlisted Sources and Quantity of Wastewater: The expected wastewater/sewage generated from the Application Site include human and pet excrement and sullage. However, the Statement omitted this important information, i.e. sources, amount and characteristics of wastewater, that may underestimate the environmental impacts of the proposed development. Ingredients of personal care products consumed by the visitors in the Application Site may pollute the stream water (e.g. detergents) and are harmful to aquatic life (e.g. sunscreen has been proved toxic to corals and coral species has been recorded in Sham Chung Wan).
o Impact on Surrounding Environment: Owing to lack of assessment of septic tanks' efficiency and maintenance plan, overloading is very likely to happen. Inadequate treatment for overloading will lead to the discharge of partially treated effluent into the ground, potentially contaminating nearby soil, groundwater and EIS and threaten the wildlife.
o Hygienic Risk: The existing village houses in the Area rely on water extraction from water well for drinking water because there is no public watermain serving the Application Site. However, the exact locations of toilet(s) and well(s) have not been indicated in the Statement. There may be risk that well water may be contaminated by the sewage seeping from septic tank, especially in soil of high underground water table, posing health risk to villagers and visitors.
Broader Environmental Management Concerns
3. While the Application proposes that visitors will be encouraged to "Take Your Litter Home", this is an unenforceable goodwill measure. Without on-site, managed waste collection practice and disposal facilities for general refuse and food waste, there is a high risk of littering, which would not only degrade the visual amenity but also attract pests and wildlife (e.g. Wild Boars) and could lead to waste entering the natural environment and watercourses, and unnecessary conflict between wild animals and visitors.
4. The proposed barbecue area, while small, will generate grease, food residues, and cleaning wastewater. The Statement does not specify how this contaminated runoff will be collected and prevented from entering the ground or any drainage channels. Such non-point source pollution is a significant contributor to the degradation of rural water quality throughout the territory.
5. The increase in human activity, including night-time occupation, raises concerns about potential disturbance to local fauna, light pollution affecting the rural nightscape, and the general alteration of the area's tranquil character.
Contradiction with the Precautionary Principle and Sustainable Tourism
6. The concept of "Ecology + Tourism" must be founded on robust ecological protection to be sustainable. The current Application leans heavily on unenforceable behavioural guidelines (e.g., taking litter home) and an under-examined sewage treatment assumption. Also, no operation/management plan, including visitor rules, staff training, etc., is devised to execute environmentally responsible tourism operation to protect tourist resources in ecologically sensitive area. This does not represent a precautionary or scientifically sound approach to developing tourism in a sensitive rural location.
7. Regulating existing sporadic camping through a managed site is a conceptually sound aim. However, management must be demonstrably effective and environmentally protective. The proposed measures, as described, lack the necessary detail, monitoring framework, and enforcement mechanisms to guarantee such protection.
The protection of Hong Kong's fragile rural ecosystems requires diligence and enforceable safeguards. We believe the proposed temporary uses, without addressing our concerns outlined above, pose an unacceptable risk to the environment of Sham Chung. We urge the TPB to reject the current Application in its presented form.
Thank you for your attention to our concerns. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).
Green Power is writing to submit our views on the captioned planning application (the Application) for temporary uses at Sham Chung, Tai Po which has been identified as a Priority Site under the New Nature Conservation Policy1. While recognizing the value of promoting tourism and recreational opportunities in rural areas, we have profound concerns regarding the sustainability and potential environmental impacts of the proposed development, particularly on the sensitive rural and natural environment of Sham Chung. We urge the Town Planning Board (TPB) members to look into the significant inadequacies in the Application.
Ecological and Hydrological Sensitivity of Sham Chung
1. Sham Chung (the Area) is located within a recognized rural and ecologically sensitive landscape in the New Territories which is a Priority Site under the New Nature Conservation Policy1. The area is characterized by its natural streams, mangroves, freshwater wetlands, coastal features, woodlands and proximity to Country Park. Various rare wildlife have been recorded in Sham Chung, including Hong Kong Paradise Fish (Macropodus hongkongensis, 香港鬥魚) and Sapphire Flutterer (Rhyothemis triangularis, 三角麗翅蜻). The shortest distance between the Application Site and the Ecologically Important Stream (EIS)2 is only about 110 metre. Any development, even temporary, should take "precautionary principle" for planning, construction, operation and management to avoid degradation of water quality, habitat disturbance, and pollution of the surrounding environment, which aligns with the general planning intention for the Area "to conserve the areas of high ecological significance" (Sec. 8.1, EXPLANATORY STATEMENT, OZP S/NE-SC/3).
Inadequate Assessment and Mitigation for Sewage and Wastewater
2. The Planning Statement (the Statement) asserts that the existing septic tank system, with a volume of approximately 9 cubic meters, is sufficient to cater for a maximum of 50 visitors per night. This assessment appears simplistic and fails to account for all sources of wastewater and environmental risk factors:
o Hydraulic Overloading: Septic tanks for village houses, e.g. exemption houses (mostly three floors, about 64 sq, metre each floor) are of domestic scale usually serve for resident number under 20 persons. The capacity of the septic tank is in doubt for the purpose of the proposed development under peak loading conditions, especially during weekend or holiday periods. Moreover, there is no assessment of the soil's percolation capacity or level of water table that significantly affect hydraulic retention time and treatment efficiency of the septic tank.
o Lack of Contingency and Maintenance Plan: The Application Site relies on a soak-away system. No plan is provided regarding the frequency and method of desludging the septic tank to avoid overflow. Leaked sewage will pose high hygienic risk and pollute neighbouring stream water and wetland habitats. For a commercial operation, a formal and frequent maintenance schedule is essential to prevent system failure. The Statement lacks an enforceable plan to ensure this maintenance will be rigorously carried out for the duration of the temporary use.
o Unlisted Sources and Quantity of Wastewater: The expected wastewater/sewage generated from the Application Site include human and pet excrement and sullage. However, the Statement omitted this important information, i.e. sources, amount and characteristics of wastewater, that may underestimate the environmental impacts of the proposed development. Ingredients of personal care products consumed by the visitors in the Application Site may pollute the stream water (e.g. detergents) and are harmful to aquatic life (e.g. sunscreen has been proved toxic to corals and coral species has been recorded in Sham Chung Wan).
o Impact on Surrounding Environment: Owing to lack of assessment of septic tanks' efficiency and maintenance plan, overloading is very likely to happen. Inadequate treatment for overloading will lead to the discharge of partially treated effluent into the ground, potentially contaminating nearby soil, groundwater and EIS and threaten the wildlife.
o Hygienic Risk: The existing village houses in the Area rely on water extraction from water well for drinking water because there is no public watermain serving the Application Site. However, the exact locations of toilet(s) and well(s) have not been indicated in the Statement. There may be risk that well water may be contaminated by the sewage seeping from septic tank, especially in soil of high underground water table, posing health risk to villagers and visitors.
Broader Environmental Management Concerns
3. While the Application proposes that visitors will be encouraged to "Take Your Litter Home", this is an unenforceable goodwill measure. Without on-site, managed waste collection practice and disposal facilities for general refuse and food waste, there is a high risk of littering, which would not only degrade the visual amenity but also attract pests and wildlife (e.g. Wild Boars) and could lead to waste entering the natural environment and watercourses, and unnecessary conflict between wild animals and visitors.
4. The proposed barbecue area, while small, will generate grease, food residues, and cleaning wastewater. The Statement does not specify how this contaminated runoff will be collected and prevented from entering the ground or any drainage channels. Such non-point source pollution is a significant contributor to the degradation of rural water quality throughout the territory.
5. The increase in human activity, including night-time occupation, raises concerns about potential disturbance to local fauna, light pollution affecting the rural nightscape, and the general alteration of the area's tranquil character.
Contradiction with the Precautionary Principle and Sustainable Tourism
6. The concept of "Ecology + Tourism" must be founded on robust ecological protection to be sustainable. The current Application leans heavily on unenforceable behavioural guidelines (e.g., taking litter home) and an under-examined sewage treatment assumption. Also, no operation/management plan, including visitor rules, staff training, etc., is devised to execute environmentally responsible tourism operation to protect tourist resources in ecologically sensitive area. This does not represent a precautionary or scientifically sound approach to developing tourism in a sensitive rural location.
7. Regulating existing sporadic camping through a managed site is a conceptually sound aim. However, management must be demonstrably effective and environmentally protective. The proposed measures, as described, lack the necessary detail, monitoring framework, and enforcement mechanisms to guarantee such protection.
The protection of Hong Kong's fragile rural ecosystems requires diligence and enforceable safeguards. We believe the proposed temporary uses, without addressing our concerns outlined above, pose an unacceptable risk to the environment of Sham Chung. We urge the TPB to reject the current Application in its presented form.
Thank you for your attention to our concerns. For any inquiries, please contact the undersigned at Green Power (T: 3961 0200, F: 2314 2661, Email: info@greenpower.org.hk).
Yours faithfully,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power
Yours faithfully,
LUI Tak Hang, Henry
Senior Conservation Manager
Green Power
1. New Nature Conservation Policy, AFCD: https://www.afcd.gov.hk/english/conservation/con_nncp/con_nncp.html
2. Ecologically Important Streams, AFCD: https://www.afcd.gov.hk/english/conservation/con_wet/streams_rivers_hk/Con_NSR/files/19_Sham_Chung.pdf
