Following is TrailWatch's response to Town Planning Board
Re: Application for the Proposed Temporary Holiday Camp (Caravan Holiday Camp) for a Period of 5 Years and Excavation of Land (Sewage Facilities) at Pui O, Lantau (No. A/SLC/155)
TrailWatch refers to the captioned Application and we are writing to express our objection to it and request the Town Planning Board not to approve the application for the following reason.
1. Not in line with the planning intention of the Coastal Protection Area (“CPA”) zoning
The applicant site is located at the CPA under the South Lantau Coast Outline Zoning Plan (No. S/SLC/21). The zoning is intended to “to conserve, protect and retain the natural coastlines and the sensitive coastal natural environment, including attractive geological features, physical landform or area of high landscape, scenic or ecological value, with a minimum of built development… There is a general presumption against development in this zone. In general, only developments that are needed to support the conservation of the existing natural landscape or scenic quality of the area or are essential infrastructure projects with overriding public interest may be permitted.”
The application site will provide rental of up to 10 caravan to holiday makers, other facilities include garden center, kiosk, pergola, storage, out-look platform and portable toilet. There is no explanation in the application of how the project will “support the conservation of the existing natural landscape or scenic quality of the area”; and as this is a holiday rental facilities, we do not agree that this is an “essential infrastructure project with overriding public interest”. Therefore, the development should not be approved according to the planning intention of the CPA.
2. Adverse ecological impacts on Pui O wetland
Pui O is rich in biodiversity. Pui O River is recognised by as ecologically important by the Agriculture, Fisheries and Conservation Department (“AFCD”). The wetlands is also of high ecological value and is one of the last remaining buffalo fields in Hong Kong. According to the report “Lantau – Hong Kong’s Jewel – A Biodiversity Study of Lantau” released by the Environmental Protection Department, the wetlands is a hotspot for birds, butterflies and amphibians. Over 180 bird species and more than 90 butterfly species are recorded in Pui O. The captioned development with a site area of about 3,672 square meters proposes to erect up 12 structures and 10 caravans which would reduce habitat and cause wetland degradation during the construction and land excavation phases. Moreover, the sewage facilities such as septic tanks, storage tanks, soakaway pits and mobile toilets would pose a risk of leaking into the wetland environment with irreversible negative impacts.
3. "Destroy First, Build Later" activities should not be encouraged
An application for a caravan holiday camp (No. A/SLC/147) at the same location and of similar scale was submitted to Town Planning Board in May 2017. Although the application was withdrawn by the applicant, an unlicensed caravan holiday camp has been in operation at the captioned location since June 2017. As advertised on the website and Facebook page, the holiday camp is available for overnight accommodation at a rate of HK1,299+ per night per caravan. According to images from Google Earth, the venue was still covered by vegetation in April 2011 but was cleared by September 2011 and filled with dry soil afterwards.
We are concerned that approving the application would set an undesirable precedent and encourage further unnecessary developments in the CPA. TrailWatch has visited the Pui O area on a regular basis since 2016. Based on our observation over the years, the dumping of construction waste or other unauthorised activities within the CPA is worsening every year. The increase in the number and scale of brownfield sites threatens the natural habitat of the CPA of South Lantau.
The impacts of the proposed development have not been adequately assessed as environmental impact assessment, traffic impact assessment, drainage impact assessment, sewage impact assessment and risk assessments have not been carried out. TrailWatch urges the Board to reject the current application to prevent further “destroy first, build later” activities within the CPA. At the same time, related government departments including Planning Department and Lands Department should closely monitor and investigate land leases and land uses in the CPA to ensure the intent “to conserve, protect and retain the natural coastlines and the sensitive coastal natural environment” is preserved.