January 2024

The Secretary,
Town Planning Board, 15/F, North Point Government Offices,
333 Java Road, North Point, Hong Kong

Dear Sir / Madam,
Green Power’s Comments Regarding Planning Application A/NE-SLT/5

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 unique and high ecological value, especially for its highly biodiverse streams and wetlands and the globally/locally important species they harbour. The proposed alignment of excavation is in close proximity to a natural stream bordering the southern edge of the valley, as well as wetlands and other habitats within and outside of the area managed by Green Power. Parts of the alignment are also within Site of Special Scientific Interest or Conservation Area zones. We opine that despite with refinement of the work methods as stated in the Method Statement, the associated disturbance, including human disturbance, noise pollution and potential dumping/stockpiling of C&D materials (see Point 3), would cause adverse long-term impacts to these vulnerable habitats and wildlife inhabiting the valley.

2. Proximity to Protected / Important Plants

Several important plant species are found growing along the proposed work alignment. There are individuals of legally protected species, including Hong Kong Pavetta (Pavetta hongkongensis) and Terete Cleisostoma (Cleisostoma simondii var. guangdongense), growing along the footpath. Although these individuals may not be classified as trees that have attained trunk diameter of 95mm or more at a height of 1.3m above the ground level and be included in the tree survey, we opine that the impacts of the proposed excavation work to these important species should not be neglected but assessed in a comprehensive ecological assessment.

3. Dumping / Stockpiling of C&D materials

The application states that the excavation of land involves an area of about 90.8 m2 with a depth of about 0.51m. Although the applicant has rescheduled the work to the dry season and proposed to fence up and clean up stockpiled materials regularly, the proposed alignment and stockpiling area are nonetheless very close to a nearby stream and wetlands. Experiences of work in remote and rural areas show that illegal dumping and stockpiling of C&D materials outside of designated stockpiling areas/normal worksite boundaries are highly likely due to poor frontline workmanship and surveillance, and the vulnerable natural habitats could easily be turned into dumping sites. In fact, such cases have already occurred in Sha Lo Tung under previous utility projects, and it is reasonable to predict that similar consequences may arise.


Although the proposed work is under the Government’s Subsidy Scheme to Extend Fibre-based Networks to Villages in Remote Areas, we would also like to stress that currently there is only one household of usual residence in Cheung Uk, and the true benefits of such work compared with the potential environmental cost should be duly assessed. The planning and management of any works within such an ecologically important site are of utmost importance to its conservation, and 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 demonstrate thorough assessment and effective avoidance of the above potential environmental impacts.

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

Yours sincerely,

Henry LUI
Senior Conservation Manager
Green Power

Yours sincerely,

Henry LUI
Senior Conservation Manager
Green Power