香港自然生態論壇保育委員會出咗呢封信:
Secretary, Town Planning Board,
15th Floor, North Point Government Offices,
333 Java Road,
North Point, Hong Kong
Dear Sir/Madam
Objection to the AMENDMENTS TO THE DRAFT TING KOK
OUTLINE ZONING PLAN NO. S/NE-TK/13
We strongly object to the proposal of amendments to the draft Ting Kok Outline Zoning Plan No. S/NE-TK/13, namely:
I. Amendments to Matters shown on the Plan
Extension of planning scheme area and associated zoning amendments at Lung Mei for a proposed bathing beach:
Item A1 - Rezoning of an area south of Ting Kok Road from “Open Space” (“O”) to an area shown as ‘Road’.
Item A2 - Designating part of the extension area as ‘Road’.
Item B - Designating part of the extension area as “O”.
II. Amendments to the Notes of the Plan
(a) Amendments to paragraphs (3), (6) and (9)(f) of the Covering Notes arising
from the extension of the planning scheme boundary.
(b) Amendments to the Schedule of Uses for the “Ozone:
(i) adding ‘Bathing Beach’ to Column 1 of the Notes;
(ii) deleting ‘Service Reservoir’ from Column 2 of the Notes; and
(iii) refining the control relating to filling of ponds in the “Remarks” arising from the extension of the planning scheme area.
Reasons are listed as follows:
1. No Necessity
There is no clear public request for such an artificial bathing beach, neither from the general public nor from Tai Po residents. Even in Tai Po District Board, there is no formal resolution on requesting this artificial beach. This matter was only discussed on Recreation, Sports and Cultural Affairs Committee meeting of the Tai Po District Board. It should be noticed that the proposal was strongly supported by only limited number of members of the Committee and quite a number of them are also members of the managing board of the New Territories Realty Association. Town Planning Board should make clear distinction between amending Outline Zoning Plan for the interest of the general public and for the personal interest of only a few persons in the expense of the interest of the Society as a whole.
Supporters of the artificial beach claimed that Tai Po District should have its own bathing beach, otherwise it is unfair to residents of Tai Po. However, because of topographic and geographical reasons, of the 18 administrative districts of Hong Kong, there are only 5 districts having bathing beach(s), namely Sai Kung District, Islands District, Tuen Mun District, Tsuen Wan District and Southern District. Obviously, it is impossible to be "Fair" to every district. There are totally 41 bathing beaches managed by LCSD. We already have too many bathing beaches but lack an easily accessible natural coast with extreme high diversity of wildlife for the public to enjoy the beauty of nature and for the students to learn from doing field work in the site.
Some supporters also claimed that the coast at Lung Mei used to be a sandy beach before the dam of Plover Cove Reservoir was built. But aerial photos taken in 1945 and 1963 (Plover Cove Reservoir was completed in 1968) clearly show that the coast at Lung Mei was muddy shore.
2. Contradiction to existing government environmental policy
On the paper LC Paper No. CB(2) 397/00-01 (03) submitted to the Legislative Council Panel on Environmental Affairs, by Agriculture, Fisheries and Conservation Department in Nov. 2000 :
Point 2 : ...Wetlands generally support rich biodiversity and perform a range of environmental functions, such as breeding and nursery grounds for wildlife and habitats for birds and many other species. They help purify water by acting like filters along waterways, provide coastal protection and serve as temporary storage of overflowing water to reduce floods. They also provide economic benefits such as fisheries, recreation and tourism opportunities;
Point 3 : Hong Kong has an international obligation to protect wetlands as China is a party to the Ramsar Convention. The Ramsar Convention (i.e. the Convention on Wetlands of International Importance especially as Waterfowl Habitat) which came into effect in 1975 aims to provide for international cooperation in the conservation and wise use of wetlands.
Point 4 : Wetlands are important to Hong Kong because they -
(i) function as “green lungs” for the increasingly developed lowland areas;
(ii) maintain an educational and scientific resource for the community;
(iii) perform environmental and ecological functions; and
(iv) provide a recreational resource.
Point 6 : In line with our international obligations to conserve and promote the wise use of wetland areas and in recognition of their value to our natural heritage and the diversity and landscape of Hong Kong, our policy is to prevent the loss of important wetland resources, to minimize detrimental impacts on wetlands from adjacent development; and to compensate for
losses which are incurred due to unavoidable development projects.
On the paper LC Paper No. CB(1) 214/04-05 (01) submitted to the Legislative Council Panel on Environmental Affairs, by Environment, Transport and Works Bureau (Now Environment Bureau) in 2004 :
Point 10 : ...Our nature conservation policy is to regulate, protect and manage natural resources that are important for the conservation of biological diversity of Hong Kong in a sustainable manner, taking into account social and economic
considerations, for the benefit and enjoyment of the present and future generations of the community.
...(c) to promote the protection of ecosystems and important habitats, and the
maintenance of viable populations of species in natural surroundings;
...(f) to promote the protection and sustainable use of natural resources that are important for the conservation of biological diversity;
(g) to provide opportunities for people to appreciate the natural environment;
Completely destroying a natural coast and the rich biodiversity for building an artificial beach is clearly contradictory to the existing environmental and planning policies.
3. Adverse and irreversible effects to the environment
According to John Morton and Brian Morton, internationally highly reputed marine biologists, in their book " Seashore Ecology of Hong Kong", :
"The inter-tidal is probably the most elaborate and complex of all habitats" and "The inter-tidal shore is rich beyond comparison in animal life”. Unless for substantial public interest, no natural coast line should be destroyed. However, in order to facilitate the development of Tai Po New Town, about half of the shoreline in this district was already scarified in the process of constructing Plover Cove Reservoir, Tai Po Industrial Estate and Tolo Highway. Now, easily accessible natural seashore only exists around Ma She Chau, Sam Mun Tsai and along Ting Kok to Tai Mei Tuk.
With very limited resources, our surveys during the period of December 2007 to February 2008 , a total number of 174 species of animals were found within the 200 meters long intertidal zone in Lung Mei. Of the 174 species of animals, at least 2 may have very high conservational value, namely:
1) Dragonet - Diplogrammus xenicus, which is rare in local waters.
2) Mud shrimp - Upogebia major, which is classified as Endangered in the China Species Red List.
As for the rest, due to the lack of relevant literature in Hong Kong, their rarity status is still not clear.
The proponent of the artificial bathing beach is now required by the Director of Environmental Protection Department to submit further information about the ecological value of the intertidal zone of Lung Mei and their studies are still in progress. It is unreasonable and unfair for the Board to make any decision at this moment, which may results in an irreversible damage to the ecosystem there.
Furthermore, construction of the proposed artificial bathing beach also involves dredging of sand from the sea bed for sand filling, no matter the sea bed is located in Hong Kong vicinity or not, the severe damage to marine ecosystem is the same.
4. Sustainability of the bathing beach
Lung Mei is a well-sheltered shore. The coast is very muddy in nature is the result of its low exposure to wave action and water current. Any alteration to the coast would not be able to last as continuous sedimentation of small particles from the seawater would quickly turn it back to a muddy shore. In order to maintain a sandy beach, the only choice would be periodic removal of the mud from the beach and periodic dredging of seabed to get sand for refilling. The result is continuous damage to our marine ecosystem.
