Dear Sir


Mr Sham’s letter in Tuesday’s SCMP would have been quite comic if it did not display such a callous and calculated abrogation of AFCD’s responsibilities to safeguard Hong Kong’s environment.  The decision not to incorporate enclaves such as Hoi Ha into the Country Parks system was contrary to the Government’s Enclave Policy, the relevant Working Paper from the Country and Marine Parks Board and the Convention on Bio-Diversity, which states, in Annex 8(e), that “sound and sustainable” planning processes must be put in place in areas “adjacent to protected areas”- exactly the position with Hoi Ha and Hoi Ha Wan Marine Park / SSSI.  Despite this responsibility, the potential impact of the zoning plan on Hoi Ha Wan has never been mentioned by AFCD.



The decision to throw the Hoi Ha enclave to the wolves of the Town Planning Board and Lands Department was made unilaterally and based on land ownership issues, not on ecological data - the Hoi Ha enclave was assessed by AFCD as having no ecological, recreational or landscape value.  AFCD’s “professional opinions” to various authorities has been incorrect and incomplete – AFCD’s species list for Hoi Ha lists 1 bird (HK Bird Watching Society lists 97), the butterfly list shows 7 species (Lepidopterist Society lists 50+), the moth list shows 0 species (HK’s foremost moth expert lists 237).  50-year old, mature lowland forest was assessed as “abandoned agricultural land”, species rich marshland was described as “abandoned farmland full of grass and weeds”.


The Convention on Bio-Diversity includes a commitment to the Precautionary Principle, which states that ecological damage should be assumed to be a threat until proven otherwise, yet AFCD has not asked for, or carried out any Environmental Impact Assessments on, for instance, the construction of 60+ new septic tanks within 100 metres of Hoi Ha Wan – under a policy that ignores the Law which prohibits such systems being built within 100 metres of a SSSI.  AFCD believes that the environmental impact of quadrupling the size of the village can be assessed by looking at each application individually, with no thought for cumulative impacts.  AFCD has refused to limit the effects of farming activities – most probably bogus activities carried out by the developers that own the farmland, who will wish to trash the areas and drain them, which will pour silt into the waters of Hoi Ha Wan, and distributing fertilizers and environmentally-damaging pesticides on plots of land which come within 5 metres of Hoi Ha Wan.


AFCD has been complacent and incompetent in protecting Hoi Ha Wan; under the Outline Zoning Plan, pollution and silt is likely to kill marine life, and sewage effluent will make the waters unfit for public use.  Hoi Ha and Hoi Ha Wan are facing an environmental disaster, whilst AFCD appears to be part of a conspiracy which will see the environment ruined purely for the benefit of developers, absentee Indigenous Villagers, who have no intention of ever living in the village, and Mainland property speculators who will buy the houses, which will not help to solve HK’s housing problems.


David Newbery

Secretary, Friends of Hoi Ha