Response to AFCD Public Consultation

The Agriculture, Fisheries and Conservation Department (Department hereafter) launched the public consultation on Enhancing Recreation and Education Potential of Country Parks and Special Areas in February 2019 with a view to broadening and diversifying visitor experience, as well as meeting growing demands for countryside recreation.

It is encouraging that the Department is proactively engaging the public in the effort to enhance the recreation and education potential of the country parks. We are however, also concerned about potential negative impacts to the natural habitat in the country parks. We believe that country parks are one of the most precious and fragile elements of Hong Kong’s legacy and heritage. They contribute equitably to the physical, mental and social well-being of our people and improve Hong Kong’s water, air and biodiversity. Any decisions on changes or potential changes to the function and usage of the country parks, including the construction of major infrastructure and facilities, require thorough and balanced assessment to ensure our natural environment is not compromised. TrailWatch has the following comments and suggestions regarding the proposal:

 

Overall view on the consultation paper

The proposals set forth in the consultation document are very general. None of them provide enough details to allow readers to have a meaningful discussion over their pros and cons. For example, there is no detail on the actual locations of the proposed facilities or the assessment criteria used to select them. Therefore, the comments made in this document are based on assumptions and our understanding of the existing condition of the country parks.

 

1. Preferences for enhancement proposals

The four proposals in the consultation document address different aspects of improving the country parks. They are not directly comparable, and therefore we are not able to pick the most suitable one. For each of the proposals, we have the following comments and suggestions:

 

1.1 Enhancement of Existing Facilities

1.1.1 Visitors’ Centres

We are glad to see the Department’s acknowledgement of the need to improve existing facilities. However, we see this as the core business of AFCD, which should be done on an ongoing basis. The proposal also suggests setting up new visitor hubs at appropriate locations. Our view is that the Department should review the usage and condition of existing visitor hubs and focus on enhancing them by refurbishing the centres and improving the content and information available to visitors. From our observation and feedback from TrailWatch users, many existing visitors’ centres are under-utilised as some of the equipment, such as monitors or information displays are frequently out of order or poorly maintained. As they exist, the centres provide little useful or up-to-date information for visitors.

1.1.2 Booking system for campsites

Regarding the setting up of an advanced booking system for popular campsites and an equipment rental service for visitors, since no information is provided regarding how the systems will work, it is hard to provide useful comments. Our concern is that any booking system should ensure fairness to all potential users and prevent abuses of the system, e.g. the reselling of booking slots for profit.

Another concern is AFCD’s authority and ability to enforce regulations. The AFCD needs to allocate more manpower and be given the authority to enforce regulations at these sites to make the booking system useful. Currently, many of the more popular campsites are already overcrowded. Travel agencies make profits by organising camping tours, creating problems of rubbish, disturbance to the natural habitat, taking of marine wildlife and natural vegetation, etc. These issues cannot be solved by a booking system alone.

1.1.3 Improving facilities for people with different abilities

We are supportive of this proposal as this is in line with our principle of Country Parks for All. TrailWatch launched a guide to accessible trails for wheelchair users in February 2019 by identifying routes that are wheelchair friendly but not currently classified as an AFCD Physically Handicapped and Able-Bodied (P.H.A.B) site. While TrailWatch will continue to identify more accessible trails, we hope to see the Department take a more active role in this.

1.1.4 Eco-tourism

We are supportive of the idea of promoting ecotourism as we believe the promotion of ecotourism can improve the general public’s understanding of and active participation in conservation. However, lack of control over the numbers of visitors or the calibre of eco-guides will negatively impact the quality of the tours and the natural habitat. The Department should introduce systems like The Recommended Geopark Guide System (R2G) or EcoGuide Australia (Certified Guide) system, and invite organisations with relevant experience and licensed tour guides to provide educational experiences for both local and overseas visitors. In this way the Department can also regulate and monitor the activities of eco-guides.

1.2 Open Museum for Historical Relics Appreciation

We support the proposal to improve the many cultural heritage sites worthy of conservation within country parks and special areas. However, it is unclear from the document what an Open Museum entails, apart from the display of interpretive panels and the introduction of educational activities. The Department should engage with villagers and historians in the design and organisation of educational activities.

We suggest the Department make use of technology, e.g. mobile apps and QR codes, to provide information which can easily be updated and tailored for users with different levels of interest and knowledge, for example simpler and more interesting content for children and more detailed information for adults. Any built facilities should be minimized and use natural and simple designs that match with the relics.

Some of the relics and cultural heritage sites already have signs and information booths available. However, many of them are poorly maintained and provide little useful or educational information. The priority of the Department should be in upgrading and repairing its current facilities at cultural heritage sites before setting up open museums in new locations.

 

1.3 Tree Top Adventure

The consultation document offers little information on the exact location of the potential sites, the baseline condition of the natural habitat, or what the impact of the facilities and activities would be on the environment.

Additionally, the Department does not articulate how these tree top adventure activities serve the purpose of deepening the public’s understanding of nature conservation. We urge the Department to explore other means to provide educational experiences which do not adversely affect the natural habitat. Please refer to Section 4 of this document for further discussion.

 

1.4  Glamping Sites and Eco-lodges

Glamping and Eco-lodges require supporting infrastructure which lead to more development pressure on the natural environment, e.g., water supply, sewerage, electricity, transportation, etc.

In addition, we are concerned about the proposal to invite the private sector to set up and manage these sites, which we elaborate on in more detail under Section 3.

 

2. View on the sites for the enhancement proposal

2.1 Lack of transparency on site selection

The potential sites displayed on p.18 of the proposal did not indicate the exact locations of the sites. While those who are familiar with the geography of country parks may be able to guess which locations are being referred to, the lack of transparency and specificity in the information provided make it difficult to provide feedback.

For example, it appears that two of the proposed site clusters either overlap with or are adjacent to existing country park enclaves in Ngong Ping on Lantau Island and Tsak Yue Wu and Pak Tam Chung in Sai Kung. Superficially, these two locations appear to be logical choices for the proposed facilities given that these areas already have existing recreational facilities and receive relatively high visitor volumes. However, in the absence of detailed information concerning the exact location, condition, existing infrastructure, ecological sensitivity etc. of each site, or the criteria/considerations used in their selection, it is impossible to provide more meaningful views.

 

2.2 Assessment and selection criteria

Similarly, ‘key considerations’ for the proposals were discussed in Section 4 but without elaboration on what they entail. The key considerations according to the consultation documents for the proposals are:

• The sites should create synergy with existing natural or manmade resources;

• The sites should be compatible with existing use of the surrounding area;

• The proposals should not cause any unacceptable and irreversible environmental impact

These are indeed critical in the consideration of the proposals. However, it is not clear what each of these points entails. For example, it is not obvious what the Department means by ‘creating synergy with existing natural or built resources’ and this is not discussed in the rest of the proposal.

As for the other two points on compatibility with surrounding areas and impact on the environment, no details are provided on how are these are defined, what the assessment criteria are, or how the proposed facilities are meant to fulfill these criteria.

 

2.3 Carrying capacity

In addition to the above issues related to site selection, we are concerned about an influx of visitors to the country parks if these new facilities are created. The report offers no data on the existing and projected number of visitors to the selected sites, making it hard for the public to understand the potential impacts on specific areas of the country parks.

A few of the more popular routes and campsites within the country parks already suffer from overcrowdedness on weekends and public holidays. Large visitor volumes and the construction of infrastructure necessary to accommodate them will inevitably have negative impacts on the environment. We urge the Department to share data on existing usage of the country parks including the methodology of calculation and their projections of usage if the proposals were to be adopted.

 

3. Views on the management mode proposed for the enhancement proposals

3.1 Concern over management by the private sector

The Department proposed inviting private sector/non-government organisations to set up, operate, manage and maintain the new facilities. Under section 4.4 the Department proposed ‘the glamping sites and eco-lodges are to be set up and operated by the private sector/non-government organisations through a land lease’. We are against this proposal as this raises serious concerns over using government land within the country parks for commercial purposes. We are concerned that once this proposal is adopted, it will set a precedent and more commercial projects will be granted in the future, including housing and other private projects.

 

3.2 Commercialization of the country parks

The country parks in Hong Kong are free to all visitors, regardless of their economic status. Anyone can equally enjoy and access all areas of the country parks. The granting of rights to the private sector to operate commercially raises concerns that people who do not have the financial means to access the facilities will be excluded from aspects of the country parks, e.g. glamping and eco-sites and the surrounding areas which will become off-limits to other visitors.

 

4. Other views on the proposal

4.1 Outdoor recreation versus entertainment

In section 4.3, it is mentioned that ‘tree top adventures have become a travel hotspot at many major parks. They offer unique experiences within the nature.’ While we agree it would be a unique experience for visitors, we do not believe that such facilities and activities need to take place within country parks.

The setting up of such facilities will cause unnecessary damage to the natural environment. Activities such as tree climbing, ziplining and grass sliding can take place in locations outside of the country parks, such as in greenbelt sites and urban fringe parks, to avoid compromising sensitive natural habitat. If they are to be developed within country parks, they should be limited to existing holiday villages to minimize their impact.

We also do not agree that popularity should be the reason for adopting a particular activity. Trends can quickly come and go and built facilities are not easily adjustable to reflect new trends in recreational activities.

While these activities might attract more visitors to the country parks, the effectiveness of these activities in ‘deepening public’s understanding of nature conservation’ is highly questionable.

More importantly, the disruption and damage to nature due to the development of facilities is hard to reverse, if it is possible at all. We urge the Department to reconsider the suitability of this proposal.

 

4.2 Enhance recreation and education potential by focusing on software upgrades

We agree with the Department’s vision to improve the education potential of the country parks. However, the current proposal focuses on the development of hardware for this purpose. We believe the natural habitat of our country parks already provide the best setting for children or adults to learn about nature and cultural heritage.

We urge the Department to focus more on the development of software instead of hardware and infrastructure in order to achieve educational goals, for example, by working closely with schools to develop materials that teachers can use in their teaching curricula.

The Department should also provide quality eco-tours with certified tour guides to ensure visitors gain a meaningful and educational experience visiting the country parks. Timely updates and enriching information about the country parks, including natural habitat, culture and heritage, trail information, etc. should be provided online and through mobile apps.

 

Website for the consultation document: www.cp-recreation.hk

You can also send your views on or before 15 May,2019 by email [email protected]