San Tin fishpond wetlands is an essential part of the entire Deep Bay Wetland. They are closely connected to the adjacent internationally important wetlands such as “Mai Po Inner Deep Bay Ramsar Site” and “Guangdong Shenzhen Futian Mangrove Wetlands Ramsar Site”, as well as the fishpond wetlands in Nam Sang Wai and Hoo Hok Wai in the New Territories. The extensive wetland habitats form the last remaining intact coastal wetland system in the Greater Bay Area, supporting over 50,000 migratory waterbirds every year.

In May 2023, the government suddenly expanded the scale of San Tin Technopole development with a 60% increase in development area and filling of around 90 hectares of fishpond wetlands. Over 175 hectares of the site encroached into the internationally recognized “Inner Deep Bay and Shenzhen River catchment area” Important Bird and Biodiversity Area (IBA). San Tin serves as a vital connection between the wetlands on the east and west sides of Deep Bay (also known as Shenzhen Bay). Opening up San Tin wetlands for development would divide the coastal wetland system of the Greater Bay Area into two fragmented parts, contradicting the national and international wetland conservation goals.

However, the government failed to recognize the potential crisis of opening up the wetlands. Instead, the government speed up the development process of San Tin Technopole. While the environmental impact assessment (EIA) report of the development is still waiting for approval, the government already kicked off the land resumption process and initiated the last public consultation under the statutory procedure.

On 8 March 2024, the government released the new "San Tin Technopole Outline Zoning Plan" (“STT OZP”), which proposes approximately 250 hectares of the "Wetland Conservation Area" (“WCA”) and "Wetland Buffer Area" (“WBA”) to rezone to innovation and technology development purposes. They also revised the "Mai Po and Fairview Park Outline Zoning Plan", which are to rezone the remaining approximately 338 hectares of “WCA” as the Sam Po Shue Wetland Conservation Park to compensate for the above wetland loss. The proposed amendments to the statutory plans include the removal of certain wetland conservation requirements and planning principles, seemingly attempting to weaken the conservation intentions of the statutory plans while incorporating the San Tin Technopole development. This may lead to significant incompatibility between future development and the adjacent sensitive wetland environment.

The amendment of the outline zoning plan is the final of all the statutory procedures! The public can submit written comments to the Town Planning Board (TPB) regarding the new draft plans on or before 8 May 2024.

We sincerely invite everyone to provide your opinions through the online form of the TPB (Option 1) or directly email your views on the “STT OZP” to This email address is being protected from spambots. You need JavaScript enabled to view it. (Option 2). Please spend a few minutes and take one more step for San Tin.

Below is a brief summary of HKBWS’s submission for your reference.

We request the Town Planning Board to:

1. Revise the "San Tin Technopole Outline Zoning Plan" (“STT OZP”) by reverting the "Other Specified Uses (Innovation and Technology)" zones within the "Wetland Conservation Area" (“WCA”) and "Wetland Buffer Area" (“WBA”) back to their original zonings, which are "Conservation Area", "Other Specified Uses (Comprehensive Development and Wetland Enhancement Area)," "Other Specified Uses (Comprehensive Development to include Wetland Restoration Area)" or other zonings effective for wetland conservation. This is to ensure that any development does not contravene the wetland conservation principles of "Precautionary Approach" and "No-net-loss in wetland". It should also explicitly state that "No-net-loss in wetland" refers to both area and function.
   
   
2. Amend the draft “STT OZP” by designating conservation zones for the second and third largest Deep Bay egretries as well as their foraging grounds. The flight paths for egrets and herons flying back and forth between their nests and foraging grounds should be designated as zones with strict height and usage restrictions. This is to ensure that any development does not exceed the current low-density development height and does not cause adverse disturbances to the adjacent sensitive ecosystem.
   
   
3. Revise the draft “STT OZP” by designating the area from the Lok Ma Chau MTR Station to the formed land parcel at the northern part of the Lok Ma Chau Boundary Control Point with strict height and usage restrictions. This is to ensure that any development does not exceed the current low-density development height and does not cause adverse disturbances to the adjacent sensitive ecosystem, thus safeguarding the ecological connectivity between Mai Po, Ma Tso Lung and Long Valley.
   
   
4. Revise the proposed amendments A1 and B in the "Mai Po and Fairview Park Outline Zoning Plan", including modifying the planning intention and the permitted uses in Column 1 for the "Other Specified Uses" zone annotated "Wetland Conservation Park". Firstly, include the important wetland conservation principles of "protecting the integrity of wetland ecosystems”, "precautionary approach" and "no-net-loss in wetland" as planning intentions. Secondly, move "on-farm domestic structure" to Column 2 to ensure that all developments and infrastructure that may have adverse impacts on wetlands are subject to strict scrutiny by the Town Planning Board.
   
   

Below are the 14 reasons for our proposed amendments:

[Unreasonable deletion and modification of conservation elements in the Planning Intention] According to the originally approved San Tin Outline Zoning Plan (No. S/YL-ST/8), both active and abandoned fishponds are indispensable parts of the wetland ecosystem based on a study on the ecological value of fishponds in the Deep Bay Area (Fishpond Study). Therefore, planning intention of "preserving the ecological value of fishponds" in the San Tin statutory plan is scientifically based. However, the explanatory statement of the draft San Tin Technopole Outline Plan completely neglected the aforementioned Fishpond Study and instead relies on an unscientific and uncomprehensive environmental impact assessment report to forcibly convert a large area of fishpond wetlands into development areas, disregarding the originally well-thought-out planning intention for wetlands.

[Contrary to Deep Bay Wetland Planning Principles] The San Tin Technopole development occupies 150 hectares of "Wetland Conservation Area” (“WCA”) and 97 hectares of "Wetland Buffer Area” (“WBA”). This development not only leads to the loss of 90 hectares of wetlands, but also damages the connectivity and integrity of the Deep Bay wetlands. As the development includes the construction of medium to high-rise buildings, the habitat quality of the adjacent internationally important wetlands is likely to further decline, resulting in the overall loss of ecological functions. The San Tin Technopole development clearly violates the "precautionary approach" and "no-net-loss of wetlands" principles as stated in the Town Planning Board Guideline No.12C.

[Lack of wetland conservation planning intentions in the latest zoning] In the past, all statutory plans in the Deep Bay area would establish wetland conservation requirements in different land use zonings based on their locations within the “WCA” and “WBA”. However, according to the latest draft San Tin Technopole Outline Plan, area within “WCA” is now zoned as "Other Specified Uses (For “Innovation and Technology” Only) zone, with the planning intention changed to "for accommodating a variety of innovation and technology uses". Up to 44 types of land uses are always permitted in this zoning, including talent apartments, commercial, hotel, and industrial uses, with building height reaching around 130 metres. Area within “WBA” is also now zoned as "Other Specified Uses (For “Mixed Use” Only) zone, allowing building developments of up to 200 metres. The latest planning not only fails to specify wetland conservation requirements, but also excluded the wetland conservation planning principles, thus the development may be significantly incompatible with the surrounding environment.

[Deletion of "No-net-loss in wetland" in the “Conservation Area” zoning] According to the explanatory statement of the originally approved San Tin Outline Zoning Plan (No. S/YL-ST/8), any changes in land use within the “Conservation Area” zoning would be handled based on the principle of "no-net-loss in wetland”. The explanatory statement clearly said that "no-net-loss in wetland” refers to the loss in both area and function. However, the explanatory statement of the draft "San Tin Technopole Outline Zoning Plan" (“STT OZP”) removed such statement in the “Conservation Area” zoning and only mentioned "no decline in ecological functions", lacking the requirement to protect wetlands in terms of area.

[Wetland loss and habitat fragmentation] The San Tin Technopole development will lead to the loss of at least 90 hectares of wetlands, resulting in a significant decline in the total coastal wetland area in the Greater Bay Area. Located in the core area of the entire Deep Bay (also known as Shenzhen Bay) wetland ecosystem, the development will disconnect the ecological connectivity between the east and west sides of Deep Bay, causing habitat fragmentation and damaging the integrity of the Deep Bay wetland ecosystem.

[Degradation of the overall wetland ecosystem] The land reclaimed for the San Tin Technopole development not only will be used for innovation and technology commercial purposes, but also will construct 6,400 units for residential, hotel, recreational, and other uses with an expected additional population of over 12,000. The population and infrastructure brought by the development will have irreversible negative ecological impacts, such as human disturbance, light and noise pollution, on the adjacent "Mai Po and Inner Deep Bay Ramsar Site" and "WCA".

[Threatening globally endangered and nationally protected species] 205 bird species were recorded at the affected fishpond wetlands, including 117 species with conservation status. The San Tin Technopole pond filling development will threaten 19 globally endangered and near threatened species, including Baer's Pochard, Yellow-breasted Bunting, Black-faced Spoonbill, Common Pochard, Ferruginous Duck, and Sharp-tailed Sandpiper; as well as 33 Class I or II protected species of China, including Eastern Imperial Eagle, Greater Spotted Eagle, and Cinereous Vulture. Filling of wetlands in San Tin will result in the loss of crucial habitats for numerous endangered species.

[Threatening breeding egret and heron populations] The San Tin Technopole development will have direct impacts on Mai Po Lung egretry and Mai Po egretry which are the second and third largest egretries in the Deep Bay area. They are the breeding grounds for over 230 pairs of egrets and herons, accounting for one-third of the breeding populations of Chinese Pond Heron and Little Egret in Hong Kong. Firstly, the development will permanently remove part of the trees used for nesting and breeding. Secondly, breeding egrets and herons will lose their foraging grounds due to extensive pond filling. Thirdly, the innovation and technology development with high-rise buildings reaching up to 105 meters will directly disrupt the flight paths between the breeding and foraging grounds of egrets and herons. If the development really deters the egrets and herons to breed in this area, this will directly threaten nearly 200 breeding pairs of egrets and herons, equivalent to almost 15% of the breeding population.

[Concerns on the disturbance caused by designating “Open Space” zoning at the egretry] The draft “STT OZP” included Mai Po Lung egretry, which is the second largest egretry in the Deep Bay, in the “Open Space” zoning. There are up to 14 always permitted uses in “Open Space” zoning, including recreational uses such as playgrounds and barbecue spots which would cause significant disturbance to the breeding egrets and herons. The land use planning is clearly contradicting to the aim of egretry protection.

[Environmental Impact Assessment not up to standard with numerous deficiencies] The draft “STT OZP” is developed based on an unsatisfactory Environmental Impact Assessment (EIA) report, which is unacceptable. The EIA report contains at least 29 serious errors or omissions in technical assessment and data, including disregarding EIA’s “avoidance” principle, insufficient ecological baseline and assessment data, significant underestimation of the impact on birds of conservation interest, breeding birds, and bird flight paths, significant underestimation of the impact on Eurasian Otter, insufficient evidence to prove the effectiveness of ecological compensation, treating “ecological enhancement measures” as mitigating measures of the development, etc.

[Neglecting impacts on traditional pond fish culture] Over 30 officially registered fishpond operators will be affected by the San Tin Technopole development. The development overlooks the contribution of traditional pond fish culture to the economy, society, and environmental sustainability. The fishpond operators in the San Tin area have been engaged in fish farming for the past half a century and have been actively participated in habitat management and conservation work in recent decade. While maintaining traditional fishpond operations, the fishponds also provide foraging and roosting grounds for waterbirds, preserving the ecological value of the Deep Bay fishpond wetlands.

[Violation of international conventions] The San Tin Technopole development is immediately adjacent to the “Mai Po Inner Deep Bay Ramsar Site” at less than 30 metres. The development requires the filling of 150 hectares of the "WCA" for innovation and technology development, resulting in severe disturbance to the Ramsar Site and directly cutting off its connectivity with the eastern wetlands, thus damaging the wetland integrity and ecological characteristics of this internationally important wetland. This goes against "avoiding negative impacts on the ecological character of Ramsar Sites " which is the primary requirement of the Ramsar Convention and wetland conservation advocated by the Convention on Biological Diversity.

[Failure to prioritize avoidance of wetland loss, contradicting to National Policies] The San Tin Technopole development does not follow the principle of "avoidance, reduction, and compensation" in its planning. It fails to prioritize alternative plans that could avoid or minimize negative ecological impacts, but instead adopts a plan that will cause significant wetland loss, contradicting to the national policies of "ecological civilization construction and high-quality development" and "priority to protection". It also goes against "restoring and rehabilitating 20,000 hectares of coastal wetlands" as mentioned in the National 14th Five-Year Plan.

[Seemingly misinterpretation of National Policies to justify pond filling] The “Development Plan for the Shenzhen Park of the Hetao Deep Bay Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone” announced by the State Council in August 2023, clearly stated that area of the Hong Kong Park within the “Hetao Deep Bay Shenzhen-Hong Kong Science and Technology Innovation Cooperation Zone” is 87 hectares, which matches with the "Hong Kong-Shenzhen Innovation and Technology Park" in the Lok Ma Chau Loop. In contrast, the "Outline Development Plan for the Guangdong-Hong Kong-Macao Greater Bay Area" explicitly emphasizes the need to "strengthen the protection and restoration of wetlands, comprehensively protect key wetlands of international and national importance in the region, and join hands to introduce measures to protect cross-boundary coastal wetlands". It appears that the authorities have selectively interpreted national policies and neglected the fact that pond filling of the San Tin Technopole development contradicts with the national wetland protection strategy. The authorities should seriously consider the provisions on ecological and environmental conservation in the National 14th Five-Year Plan and the "Outline Development Plan for the Guangdong-Hong Kong-Macao Greater Bay Area".