海下 Hoi Ha
以下是本會對海下分區計劃大綱草圖提出的意見:
The following are the Society's comments on the Draft Hoi Ha OZP:
The Hong Kong Bird Watching Society (HKBWS) would like to raise our concerns on the Draft Hoi Ha Outline Zoning Plan (OZP). In the 2010 Policy Address, Donald Tsang promised to include Country Park enclaves into CPs or determine their proper uses through statutory planning in order to meet conservation and social development needs. However, the Draft Hoi Ha OZP does not provide sufficient protection to the natural environment of Hoi Ha and we would like bring your attention to the following concerns:
1.
Composition of Bird Population at Hoi Ha
Aside from the existing village,
the surrounding natural habitats of Hoi Ha support a diverse populations of birds, 104 species have been recorded at the various habitats of Hoi Ha. Of the total species of birds recorded, 21 are considered to be of conservation interest (Table 1). The significance of the bird composition at Hoi Ha correlates with the naturalness and diversity of different habitat types (natural stream, secondary woodland, marsh and coastal area).
Flycatchers, warblers, babblers and thrushes roost and forage at the secondary woodland. Waterbirds including terns, ardeids and kingfishers forage along the coastal area and owls, wagtails and raptors forage in the natural stream. Out of these groups, a number of species are of Local Concern and listed under Class II protection in China (Table 1). We urge the Town Planning Board to acknowledge the ecological value of the bird community and to take into consideration protecting these associated habitats from any development and human disturbances.
2
Impacts to Natural Habitats Resulting from Village Zone
The proposed V zone where no small houses currently exist is made up of secondary woodland and disturbed woodland. Some parts of the V zone edge also borders an existing marsh and natural stream (Figure 1). The provision of land for small house developments would not only result in the loss of the woodland habitats, it would also result in human disturbances to the natural stream (Figure 2) and tidal creek which are foraging grounds Brown Fish Owls. Brown Fish Owls are scarce residents in Hong Kong which feed in undisturbed, unpolluted lowland streams and tidal creeks. This species is considered to be of Regional Concern and it is also listed under Class II in the List of Wild Animals Under State Protection in China. Their habitat requirements are particular and with the low number of natural stream with undisturbed tidal creeks remaining in Hong Kong, this habitat type in Hoi Ha should be highly protected. The proposed V zone should be restricted to where the existing small house development is located and not encroach natural habitats.
3
Replace Green Belt Zone with Conservation Area and Coastal Protection Area
The proposed GB zone should be changed to CPA and CA in order to provide adequate protection to the natural coastline, natural stream, marsh (Figure 3) and the associated woody and shrubby areas. The marsh also supports a very rare plant species,
Gymnanthera oblonga. Given that the list of permitted uses (Column 1) in GB includes agriculture use, barbecue spot, government use (police reporting center only), tent camping ground and wild animals protection area these habitats of high ecological value would be destroyed.
4
Amendments to Column 1 of Conservation Area and Coastal Protection Area
Land uses that could result in direct loss of natural habitat and indirect impacts to Hoi Ha Wan and other natural areas should be either completely removed from the schedule of uses or removed from Column 1 of schedule of uses and moved to Column 2 which requires a permit. As such, we propose agriculture use and on-farm domestic structure to be totally removed from the schedule of uses. Whilst nature trail and wild animals protection area to be moved to Column 2.
5
Impacts to Hoi Ha Wan Marine Park
5.1
Sewage Discharge
The coastline of Hoi Ha borders the marine waters of the Hoi Ha Wan Marine Park, an area that has been known to be of great ecological interest since the 1980s when it was first recognized as the Hoi Ha Wan Site of Special Scientific Interest (SSSI). Hoi Ha Wan Marine Park supports a high diversity of corals, 64 species of stony corals and over 120 species of coral associated fishes. Additionally, six species of mangrove plus other marine invertebrates have also been recorded there. Aside from natural resources, seven artificial reefs have been deployed there as part of the Hong Kong Artificial Reef Project. These ecological sensitive receivers have been known to be threatened by water pollution and sediments from Tolo Channel dating all the way back to 1989. The change of landuse in Hoi Ha as proposed in the draft OZP would further increase the pollution load into Hoi Ha Wan Marine Park. Small house development in the V zone would allow for 94 more houses to be built, which would heavily increase the amount of nutrient-rich pollutants in Hoi Ha Wan as the sewage from these houses would not be treated at a sewage treatment plant, but instead rely solely on on-site septic tanks and soakaway systems.
5.2
Agriculture Land Use
Due to the close proximity to Hoi Ha Wan Marine Park and the topographic characteristics of Hoi Ha being that surface runoff drains into Hoi Ha Wan, agricultural land use should be kept at minimum to prevent increase of nutrient load in Hoi Ha Wan. Agricultural uses in GB should be removed from Column 1 (always permitted) but instead by only permitted after further considerations of the Town Planning Board (Column 2). We also suggest to remove agriculture uses in CPA and CA zone (refer to Section 4).
We are concerned that the additional sewage discharge and agricultural land uses would adversely impact the marine ecosystem of Hoi Ha Wan Marine Park as corals and the associated reef fishes are sensitive to excess nutrients and turbidity. Deteriorated water quality would result in a lower coverage of hard corals and decline in fish abundance .
6
Hoi Ha as an Environmentally Sensitive Location Under the EIAO Guidelines
If we consider the village house development as a whole and apply it to the EIAO guidelines, it qualifies as a schedule 2 designated project under category Q1, “All projects including new access roads, railways, sewers, sewage treatment facilities, earthworks, dredging works and other building works partly or wholly in an existing or gazette proposed country park or special area, a conservation area, an existing or gazette proposed marine park or marine reserves, a site of cultural heritage and a site of special scientific interest” . The cumulative impacts of the potential 94 additional small houses need to be assessed properly. The V zone is located less than 500 m from a Marine Park/SSSI, adjacent to the proposed CPA and CA and within a site of archaeological interest and within 500 m from the Hoi Ha Lime Kiln (which is also considered as a site of archaeological interest) (Figures 1 and 4). We are concerned that the extensive area of V zone would result in adverse environmental impacts to these sensitive receivers nearby. For a sensitive site like Hoi Ha, we urge the Town Planning Board to take into consideration the cumulative impacts (direct and indirect impacts) of such large V zone.
The HKBWS respectfully requests the Town Planning Board to consider our concerns on the draft Hoi Ha OZP. Based on the reasons above, we hope the Town Planning Board will consider to incorporate Hoi Ha as part of the Sai Kung West Country Park.
