Policy Comments & Advocacy

We would like to express our concerns regarding the environmental impacts likely brought about by the entitled application.

1. Proximity to Ecological Sensitive Areas

Sha Lo Tung is well-known for its ecological value, especially for its highly biodiverse streams and wetlands and the globally / locally important species they harbour. The stream sections running through the valley and their riparia are listed as Site of Special Scientific Interest (SSSI), while the nearby wetlands, including the restored wetlands currently under Green Power’s management, are either designated as SSSI or Conservation Area to restrict the type of development or construction works within and around these sensitive receivers.

The plan of the entitled application shows that the proposed alignment of excavation is in close proximity to a nearby natural stream bordering the southern edge of the valley and the managed wetlands near Cheung Uk. Parts of the alignment are in the zoning of SSSI and Conservation Area. The proposed location of the common manhole is only meters away from the water inlet of the eco-pond in the managed wetland area of Sha Lo Tung.

We opine that the associated disturbance, including possible illegal dumping / stockpiling of C&D materials (see below), human disturbance and noise pollution, would cause undesirable impacts to these vulnerable habitats, including the restored wetland.

2. Dumping / Stockpiling of C&D materials

The application states that “excavation of land that involves an area of about 229 m2 with depth of about 0.58 to 1.2m and width of about 0.5 to 1m are proposed”, meaning a large amount of excavated materials will be produced in the process. Experiences show that illegal dumping / stockpiling of such C&D materials outside of designated storage areas / beyond normal worksite boundaries are highly likely, and natural habitats would easily be turned into dumping sites, especially for cases without prudent preventive and works management measures.

Such dumping / stockpiling activities also pose risks of water pollution if the responsible party fails to avoid loose materials from being washed into the nearby water bodies by surface runoff during rainstorms.

3. Unclear scale of earthwork

Only a range of depth and width are provided in the application, the scale of the earthwork is not well stated. It is difficult to assess accurately the impact of the proposed application to the environment, as well as any mitigation measures to be taken in response to the earthwork. Without clearly stated scale, it is also difficult to evaluate the necessity of the application.

Conclusion

We understand the need of local villagers to have access to utility services, but would also like to stress that planning and management of works within such an ecologically important site are of utmost importance to its conservation, and that the planning intention stipulated in the Outline Zoning Plan should be upheld. We opine that the application should not be approved unless the applicant could provide more information and support on how the above potential environmental impacts could be effectively avoided.

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