Policy Comments & Advocacy

Green Power would like to draw your kind attention to our concerns about the above-captioned proposed development.

Land Uses

1. The proposed development is located within the globally important Inner Deep Bay wetland system. Any proposed land uses should not compromise the ecological functions of the designated “Wetland Conservation Area” (WCA), “Wetland Buffer Area” (WBA), and planned Wetland Conservation Parks.

2. A large piece of farmlands around Ma Tso Lung San Tsuen and Ma Tso Lung Shun Yee San Tsuen will be affected by the proposed development. These farmlands are precious agricultural flatland and wetland resources in the Northern Metropolis. Therefore, the existing farmlands and associated facilities such as irrigation system should be preserved as far as possible. Inactive farmlands revitalization can be incorporated to facilitate multiple functions such as ecological enhancement and linkage, carbon storage, relieving urban heat island effect and lowering flooding risk.

Ecology

3. The fishponds in Hoo Hok Wai and outside the Lok Ma Chau Loop are one of the major ecological sensitive receivers adjacent to the proposed development. The ecological impacts to these important wetlands induced by the proposed development should be fully assessed and mitigated. Provided that there will be a prominent increase in population in the Project Site, the road and footpath networks should be designed in a way that avoids disturbance to these ecologically sensitive areas, especially the Wetland Conservation Parks.

4. The Ma Tso Lung (seasonal) marsh is the significant habitat for dragonflies Rhodothemis rufa and Urothemis signata⁽¹⁾, an ecoIogical impact assessment for the marsh-dependent and aquatic species should be conducted throughout the wet season.

5. In addition, the Ma Tso Lung Stream and its tributaries are interconnected to the marshy habitats and Inner Deep Bay Ramsar Site, therefore ecological impacts brought about by alternation of the streams and hydraulics should be avoided.

6. More importantly, the comprehensive ecological assessment should be conducted for Ma Tso Lung Stream and its ecological functions as foraging and breeding habitats for flora and fauna, connectivity between hilly terrestrial, lowland countryside and wetlands habitats, etc, should be adequately addressed with sufficient baseline data.

7. The physical settings of natural stream courses, including its beds and banks, should not be altered or disturbed. Any river works in the proposed development area should not trigger further need of major river works in upstream and downstream.

8. Blue-green infrastructures should not be considered as a proactive conservation measure to encroach any identified or potential important aquatic and riparian habitats. No river channels should be decked because decking of river/stream channels escalates flooding risk owing to the altered local precipitation pattern under climate change.

9. Aquatic, river course and riparian habitats should not be disturbed or encroached by developments and associated activities such as discharge of effluent and runoff, vehicle parking, etc. There should be buffer areas on both riparian zones along streams and tributaries in the proposed development to protect the water quality, ecology and landscape of the streams. Establishment of such buffer areas can avoid spillage of environmental impacts to Hoo Hok Wai Wetland Conservation Park through the drainage system/streams in the proposed development.

10. Proper measures should be taken to avoid bird collision on glass walls. Glare impacts from lighting of the proposed project on surrounding areas and wildlife should be minimized, if unavoidable, by adjusting the light intensity and illumination angles.

11. It is recommended to select native tree species for the compensatory tree planting. Post-planting monitoring and care should be taken place accordingly.

Water Quality and Hydrology

12. Being an engulfed water body, Deep Bay is limited in its self-purification power and has already been overloaded with pollution. Since the proposed development 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.

13. 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.

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).