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STILL MAJOR PROBLEMS
WHICH CAN BE FIXED!
Zoning for Building or Conservation?
New Green Belt Area.
Defining the “NEED” for Housing.
POOR COASTLINE MAPPING
Detail from Proposed OZP Map
PHOTO FROM “A”
THIS PHOTO IS TAKEN FROM THE BOUNDARY OF THE MARINE PARK
PHOTO FROM “B”
PHOTO FROM “C”
PHOTO FROM “D”
The PlanD Maps give the impression
that there is at least 40 metres
between House 21A and the sea.
SO – WHERE IS THE COASTLINE?
Marine Park Boundary is arbitrary and out to sea.
Marine Park Boundary is not the High Tide Mark.
Marine Park boundary is not the beach line.
Before Coastal Erosion, village was 40-50 metres from the sea.
Now, the beach comes as close as 10 metres from the old
(ruined) village walls.
COASTLINE CONCLUSIONS - 1
Planning Department has recognised the need for the CPA to be at least 25
Planning Department Maps show the CPA as being 30 metres wide in front
of the old village.
Reality is that CPA is, effectively, 10 metres wide because Coastal Erosion
has changed the boundary between sea and land.
The CPA needs to encroach upon the existing village footprint because in
the real world the coastal boundaries have changed.
10 Metres is insufficient to prevent building works causing:
o Liability to continued erosion.
COASTLINE CONCLUSIONS - 2
Include the Old Village Within
the Coastal Protection Zone.
This solution will not stop all building activities in the area
but it will ensure that:
• any building will not cause pollution to Hoi Ha Wan, or
• lead to the resumption of Coastal Erosion.
BOUNDARY OF CPA
V-Zone / CPA
MAPPING OF HYDROLOGY
Allowed on privately-owned land in CPA, CA and GB.
95% of GB(1) area is owned by developers.
Who is likely to want to “Farm” these areas?
Farming is often used as a pretext for “Trashing” an
area prior to applications for development.
Destruction of Woodland.
Draining of Woodland.
Draining of Marshland
“FARMING” IN THE GB(1) AREAS
The present hydrological system of the GB(1)
Woodland and Marshland effectively filters runoff and
produces clean water running into Hoi Ha Wan, which
is vital for its survival.
If uncontrolled farming is allowed:
Trees cut down will leave exposed soil.
Soil will be washed down into Hoi Ha Wan.
Silt will cover the corals and other marine life.
Marine Life will be killed.
CONSEQUENCES OF CLEARING THE
HOI HA GB(1).
PAK SHA O
Will involve use of:
These POLLUTANTS will wash into Hoi Ha Wan causing:
• Algal blooms.
• De-oxygenation of water.
• Poisoning of Marine Life.
Move “Agricultural Use” into Column 2 of the schedules for CA,
CPA, GB and GB(1).
Not prevent small-scale, sustainable, organic and
environmentally-friendly farming activities.
Will prevent areas being “Trashed” by bogus farming activities.
A bona fide farmer can apply to the TPB for permission to carry out
farming activities which will not harm the environment and, in
particular, will not cause pollution to Hoi Ha Wan.
PlanD has recognised that AFCD’s ecological assessments were flawed and
PlanD has recognised that NGO data “have merits” – i.e. they are correct.
PlanD say they are zoning the area for conservation but Green Belt is seen
as a “reservoir of future building land” - as seen by recent Government
If area is seen as available for future development, then owners
(developers) will “trash” the area to destroy the ecological value.
If PlanD mean what they say, then these areas should be:
THE CASE FOR CONSERVATION AREA
Hoi Ha has NO mains Sewage System.
All houses in Hoi Ha are served by Septic Tank Systems.
STS are designed to produce effluent which flows through
the soil and is purified by soil bacteria.
The greater the “Step-Back” distance between a STS and a
receiving water, the greater the purification.
SEWAGE - 1
Measurable levels of E.coli found close to the beaches at
Hoi Ha - 2 independent sources.
Measurable levels of EDCs (Endocrine Disrupting
Compounds), such as nonylphenol (degrade of detergent),
bisphenol (a material for plastics) found close to beaches
at Hoi Ha – paper to be published soon by HKU.
These pollutants can have only come from STS at Hoi Ha,
which have been licensed in accordance with EPD POLICY.
SEWAGE - 2
TECHNICAL MEMORANDUM ON EFFLUENT STANDARDS:
“Within the coastal waters are special areas that need specific restrictions.
These areas include bathing beaches, sites of special scientific
interest…..Paragraph 9.1 lists the restrictions.”
“No new effluent will be allowed:
• Within 100m of the boundaries of a gazetted
• Within 200m of the seaward boundaries of a …. site of special scientific
interest, and within 100m of the landward boundaries;
SEWAGE - 3
EPD POLICY does not take account of this LAW.
EPD POLICY allows the siting of Septic Tank Systems within
30 metres of a SSSI rather than the STATUTORY 100
EPD POLICY does not prevent pollution from Hoi Ha’s
existing STS from entering HHW.
Under the Draft OZP, the number of STS will MORE THAN
SEWAGE - 4
PUBLIC HEALTH HAZARD
DESTRUCTION OF MARINE LIFE
Parts of the proposed V-zone are WATERLOGGED
with a HIGH WATER TABLE and NUMEROUS
MAKES THE AREAS UNSUITABLE FOR SEPTIC TANKS.
THE STEP-BACK DISTANCES SHOULD BE INCREASED
TO PROVIDE THE SAME LEVEL OF PURIFICATION AS
IN IDEAL CONDITIONS.
SEWAGE - 5
in November 2013
High Water Table
The existing Septic Tanks are causing pollution in Hoi Ha Wan.
The OZP allows for up to 40 new houses, the majority of which will be within
100 metres of Hoi Ha Wan.
If the incorrect maps are used for planning, septic tanks may be sited on the
site of the old village, 10 metres or less from the beach.
Much of the V-zone has soil hydrology which precludes effective treatment
of sewage effluent.
A proper planning process must assess the CUMULATIVE IMPACT of
adding more sewage effluent to the hydrological system.
SEWAGE - 7
The possible consequences of this situation are:
Increasing levels of E.coli which may render the beaches UNSAFE because of PUBLIC
The increase in nutrients in the Wan will cause a decrease in oxygen levels, which
will DAMAGE THE MARINE LIFE.
Increasing levels of detergents and non-biodegradable detergents, which are TOXIC
to marine life, especially CORALS.
The DESTRUCTION of Hoi Ha Wan as a place for conservation and recreation.
AN ENVIRONMENTAL CATASTROPHE
SEWAGE - 8
EPD Claim there is no pollution of Hoi Ha Wan at
SEWAGE - 9
EPD POLLUTION MONITORING
EPD has 3 Pollution Monitoring
Stations at Hoi Ha Wan.
Nearest is more than 1 kilometre
from beaches and in an area
regularly flushed by Tolo Channel.
Inner reaches of Hoi Ha Wan have
slow flushing rates, especially in
dry season – pollutants will not be
A lagoon has recently formed at
the stream estuary which will trap
and concentrate pollutants.
Hoi Ha after development will no longer be a “small” village.
Individual Septic Tank Systems will not provide long-term
protection to Hoi Ha Wan.
No more building should be authorised until a long-term
solution for the disposal of sewage is constructed:
• Sewage mains (piped) system.
• Local, environmentally-friendly sewage plant.
This solution should include the existing houses.
NEW GREEN BELT AREA - 1
NEW GREEN BELT AREA - 2
Area is not “Flat” as claimed by AFCD – look at the
Area is difficult to penetrate – assessment has been done
purely by reference to an aerial photo.
Area is old woodland – has never been farmed.
Area is not “closed canopy” because it is strewn with large
This is a MATURE, distinct and un-surveyed ecosystem.
NEW GREEN BELT AREA - 2
Why has AFCD advocated the designation of a large part of the OZP as area which will be seen as a
reservoir of future building land, despite the following factors:
AFCD has presented no scientific data on the ecology of the area.
The fact that a significant stream flows through the area and into Hoi Ha Wan Marine Park.
Part of the area has been designated as “Fung Shui” Forest by AFCD.
Access is almost impossible.
The area is totally natural – it has never been used for farming activities.
Green Belt is meant to “define the limits of urban and sub-urban development areas by natural
features and to contain urban sprawl” not to be an island in the middle of a Conservation Area.
NEW GREEN BELT AREA - 4
Based on figure of 84 given by VR.
o Total number of potentially entitled IVs worldwide?
o Number of Houses which can be crammed in to private land?
o Who knows??
Figure has not been subject to any kind of Audit,
Verification or Scrutiny.
Increased to 94 by TPB. (Apparently, 15 applications, 5 already
THE DEMAND FOR HOUSING - 1
THIS IS NONSENSE!
Quotes from Tung A Village Representative (SCMP 29 March 2014):
“Of course I have asked for more than the actual need. It’s a game”.
“To me, the number is meaningless”.
“The number is just a rough estimate”.
“Many of the next generation are staying in the UK and are unsure if they will come back”.
WHY ARE THESE FIGURES BEING USED AS THE BASIS FOR THE OZP?
THE DEMAND FOR HOUSING - 2
In the last 18 years, 7 new houses have been built.
NONE of these houses are occupied by IVs.
Therefore, the NEED for housing under SHP in last 18
years has been ZERO.
Who actually believes that 94 “Sons of the Village”
will return to live and work in Hoi Ha in the next 10
THE NEED FOR HOUSING - 1
The proposed development will NOT help to solve Hong Kong’s
The proposed development will NOT provide houses for
Who will benefit?:
• Property Speculators.
• Absentee Indigenous Villagers.
THE REQUIREMENT FOR HOUSING
No-one has asked them.
“Villagers” consulted are IVs, most of whom do not live in
the village and are only interested in the money to be
made from the SHP.
More than three-quarters of the resident villagers have
written to the Rural Committee saying that the views
expressed by the Committee to the TPB do not represent
the views of the VILLAGERS who reside at Hoi Ha.
WHAT DO THE VILLAGERS WANT?
“The primary function of the Rural Committee is to protect the rights of the
indigenous population….particularly to safeguard their rights on village
“We hate to use the word outsiders but in reality that is what you are”.
“The spirit of the small house policy is to provide the indigenous males to
apply….to build a small house in Hoi Ha”.
“Where people live is irrelevant. It is their right we are talking about”.
“If sewage is not properly managed, even one house can cause the
REPLY FROM THE RURAL
Does the Government support the Rural
Committee’s statement that an
Indigenous Villager’s eligibility to build a
small house has nothing to do with his
intention to ever occupy the house?
If the TPB accepts the Rural Committee’s view and the VR’s demand for housing:
It sets a bad precedent for other CP enclaves.
VRs can ask for any number and planning decisions will be made without this number
Opens up the floodgates for 100’s of thousands of applications from IV’s who have no
intention of ever living in “their” NT village.
The demand is infinite.
Where will the land come from?
A LONG-TERM PLAN for the village should be constructed with input from KEY
INDIGENOUS VILLAGERS with a GENUINE NEED for housing in the village.
HIKERS, BIKERS, DIVERS etc. – the PEOPLE OF HONG KONG who use and enjoy Hoi
Ha and Hoi Ha Wan.
THE WAY AHEAD - 1
IN THE MEANTIME, THE OZP NEEDS TO BE CHANGED
The coastline needs to be properly mapped and the CPA extended to ensure that it provides at
least a 25 metre barrier between the beach and the V-Zone.
“Agricultural Use” needs to get permission from TPB (Column 2).
No Septic Tanks should be licensed within 100 metres of the beaches or 30 metres of a stream.
The proposed new Green Belt needs to be scrapped.
OZP’s for CP enclaves need to be planned taking into account a realistic estimate of the NEED for
housing under the Small House Policy, not the VR’s DESIRE.
Government needs to make a clear ruling on the INTENT OF THE SMALL HOUSE POLICY – is there a
requirement for the Small House applied for to be a place of residence for the Indigenous Villager
applying? If so, what checks will be carried out to ensure that applications are genuine.
THE WAY AHEAD - 2