Policy Comments & Advocacy

Corresponding to the town planning application for the Proposed Education Centre and Associated Excavation and Filling of Land (refer to the Facility hereafter), we would like to raise the following concerns in different aspects, including stream pollution, vegetation impairment, potential threats on butterfly ecology and etc.

The subject site is very close to a natural stream (i.e. less than 20 meters away from the stream course) leading to Shui Hau Wan which is an important spawning and nursery ground of Horseshoe Crabs. Any intended or accidental spillage of sewerage at the site, no matter in its construction or operation phases, would have irreversible impacts on the stream, Horseshoe Crabs and the ecological-sensitive Shui Hau Mudflat. In view of this, we would like to reiterate our concern on the followings:

• During construction, how does the contractor store and discharge sewage generated?

• Are there any protocols to minimize sewage and construction runoff to be generated?

• Are there any special means to confine sewage in the construction site and avoid spillage of sewage?

• Are there contingency measures to tackle situations if spillage was spotted during construction?

Preservation of water resources for the nearby stream is one of our main concerns. In fact, it is not uncommon for construction workers to extract freshwater from nearby rivers or streams for construction use. To ensure this is not going to happen in the construction of this facility, we would like to know if any measures could be imposed by the applicant or its contractor.  

In a meeting with representatives of CEDD and AECOM dated 20 May 2026, we were noted that an underground sewage storage tank would be deployed to manage the black water in the facility. As this is the only means of the facility to get rid of its black water (i.e. at least before Shui Hau is covered by DSD's village sewerage programme), if there was any slippage on the system, disastrous ecological events could be foreseen. We appreciate if the following concerns would be clarified. If situation permits, we would like to urge the applicant to deploy a second black water management system, which aims to complement the existing design with underground sewage storage tank.    

• What is the designed capacity of the underground sewage storage tank, in the context of registered visitors and walk-in visitors?  

• What is the pumping frequency of the sewage storage tank?

• Are there contingency measures to avoid and tackle overflow of the sewage storage tank, in particular during unexpected high visitor traffic or adverse weather conditions?

• Is it possible to deploy a second black water management system which can complement the underground sewage storage tank?

Currently, the application site is occupied by massive shrubs and individual trees. It is likely that all vegetation within the project area will be removed before and during construction. However, existing riparian habitats near the stream course and backshore habitats must be well-protected and left undisturbed. And all vegetation in the riparian and backshore zones must be preserved. Riparian vegetation always supports a vast amount of biodiversity, including herpetofaunas, fishes, insects and other aquatic invertebrates. Vegetation along the coast near the project site is an integral part of the ecology, surface geology and landscape of the natural coast and intertidal mudflat. Moreover, backshore vegetation can enhance climate resilience of soft seashore against coastal erosion and storm surges, and improve coastal water quality for intertidal habitat by filtering the contaminated surface runoff.

According to Green Power's survey record conducted from 2019 to 2024, a total of 141 butterfly species (54% of number of species recorded in Hong Kong) were recorded Shui Hau, including 3 "Very rare", 13 "Rare" and 46 "Uncommon" species. We opine that the rich biodiversity of butterfly in the proximity of the project site is supported by mosaic of natural, semi-natural, vegetated and watercourse habitats which provide foraging grounds and nectary and larval foodplants. In order to minimize the impacts on butterfly community, their habitats outside the project site should not be disturbed by the project. Vegetation or water bodies should be retained or re-provided with ecologically friendly maintenance to act as buffer. Within the project site, shrublands, wetlands and plantation should be allocated to allow growth of larval foodplants for butterfly species of conservation importance.

Local research revealed that microplastic threatens the survival of juvenile Horseshoe Crabs. We are deeply concerned the waste brought about by the Facility. We would like to consult are there any measures to prevent plastic waste from reaching the mudflat during construction phase and operation phase.

We would appreciate some insight into the concerns we have addressed above. And Green Power is glad to explore this further with the project team.