Town Planning Board,
We oppose the amendment to the draft Tsing Yi Outline Zoning Plan (OZP) No. S/TY/31, which proposes rezoning a site in Liu To, Tsing Yi from “Green Belt” to “Residential (Group A) 5”. The site is not suitable for residential use and the proposal report is misleading. The District Council agreed to postpone the discussion on this project however the project report was then submitted to the Town Planning Board. The opinion of the District Council is disregarded. The project proponent is also suspected of rushing through the planning application. We urge the government to withdraw this and retain the proposed site as “Green Belt” due to the following reasons:
1. Puts future residents in danger
According to the “Report of Potential Risks in Tsing Yi” in 1982, incidents at the Liquefied Petroleum Gas storage can affect an area of the radius within 1,000 meters. In 1985, Environmental Protection Department suggested to Lands and Works Branch that the residential area must be kept at least 1,000 meters from the oil depots. Green Belt serves as a physical barrier separating the oil depots at the south and west of Tsing Yi and the residential area at the northeast, lowering the risk of these dangerous industrial facilities to the densely populated area nearby. The proposed site lies within 1,000 meters range from the oil depots – not suitable for residential use. Moreover, the proposed residential buildings will be taller than the existing ridgeline, which will lose its function as a natural barrier. Any explosion from the oil depots threatens the lives in the residential area. The government has not carried out any risk assessment but proposes to develop an area of high-risk and claims that preventions are not needed. This planning application puts future residents in danger.
2. Contravenes the planning intention of Green Belt and set up a bad precedent
Based on the draft Tsing Yi Outline Zoning Plan (OZP) No. S/TY/31, the planning intention of Green Belt zoning is to “primarily for the conservation of the existing natural environment amid the built-up areas/at the urban fringe, to safeguard it from encroachment by urban-type development, and to provide additional outlets for passive recreational activities” . It emphasizes the Green Belt “serves the purpose of protecting the existing ridgeline” and “there is a general presumption against development in the Green Belt”. This proposal clearly contravenes the planning intention of the Green Belt. The approval of this proposal will set up a bad precedent for developing Green Belts. Urban development will continue to encroach on the Green Belt of Tsing Yi and the rest of Hong Kong.
3. Erases ecologically valuable streams
The approval of this proposal will erase Liu To Hang, the largest streams with high ecological value in Tsing Yi and the secondary woodland along the watershed. Over 1,260 trees will be chopped down. Important plant species regulated by law will be removed, including Incense Tree (Aquilaria sinensis) and Lamb of Tartary (Cibotium barometz) with different conservation statuses. The habitat and breeding ground of species with conservation value such as the Nanhaipotamon hongkongense endemic to Hong Kong will be destroyed. This proposal will cause irreversible habitat loss and threaten species regulated by law and those of conservation value.
4. Underestimates ecological value and the environmental impact
The Environmental Impact Assessment did not specify the baseline ecological study in detail. There is a lack of research data on amphibians, reptiles, and birds. Multiple important species around Liu To Hang were missed out from the report of this planning application, they are: Lamb of Tartary (Cibotium barometz) regulated by law, bird species of conservation value: the Crested goshawk under Class II national protection, the vulnerable Common emerald dove (Chalcophaps indica) under China Red Data Book Status, the White-throated kingfisher (Halcyon smyrnensis) of “locally concerned”, and over 13 species of snakes including the globally vulnerable Chinese Cobras, the critically endangered Burmese Python under China Red Data Book Status. Important species are excluded from the report underestimating the ecological value of the proposed site.
5. Contravenes the Government’s standard of Green Belt with development potential
The development potential of Green Belts is addressed in the last two policy address. Suitable Green Belt areas for development are “devegetated, deserted or formed” land and Green Belt zones with “vegetation and low buffer effect and conservation value”. However the Green Belt area in this proposal is fully covered with thriving vegetation, some of those with high ecological value, thus the proposal contradicts the Government’s standard of Green Belt with development potential aforementioned.
6. Go for the easy option – “Develop Brownfields First, Green Belt Later”
According to the Hong Kong Brownfields Report 2021 by Liber Research and Greenpeace, about 1,958 hectares of brownfields were identified, different from Government data by 380 hectares which are about 2.3 times of the Fan Ling Golf Course . The proposed site is high-risk of being affected by explosions from the nearby oil depots and covers ecologically important streams. It is challenging to carry out development projects at a 30-meters-high ridgeline. The proposal is not cost-effective. The long development time will slow down the housing supply. Moreover, there is no contradiction between housing development and nature conservation. The Government should ensure justice in land planning and allocation using different policies and follow the principle of “Develop Brownfields First, Green Belt Later”.
7. Misleading traffic impact assessment
The latest traffic impact assessment showed the utilisation rate of Tsing Yi Road West and Tsing Hong Road remains at an acceptable level, about 70-80%. This is different from the traffic impact assessment for the development project of Ching Fu Court. The development projects of multiple housing estate including Ching Fu Court, The Grand Marine and The Met.Azure will soon be completed, providing about 4000 flats. The utilisation of transport system at the southwest of Tsing Yi will be multiplied. The future development plans in Tsing Yi were not considered in the latest traffic impact assessment. It is worth noting that the two trunk roads, Ching Hong Road and Tsing Yi Road West, connected with the proposed development project will very likely be overloaded.
8. Ignores people’s livelihood
There is a lack of complete ancillary facility around the proposed site. Wet market is nowhere near. Medical facilities such as clinic and evening out-patient services, shops and parking spaces in Tsing Yi are persistently in short supply. According to Tsing Yi Outline Zoning Plan No. S/TY/30, the 10,300 population in the proposed development project will lead to a shortage in 131 units of community care service facilities, 858 units of residential care homes for the elderly (RCHEs) and 1,160 hospital beds in Tsing Yi. The proposed development plan will exacerbate the persistent shortage in ancillary facilities and burden the existing transport system and community facilities.
9. Screen-like buildings affect natural landscape and ventilation
The three housing buildings in this proposal will be at a level of around 220mPD (Principal Datum) which is about 50 storeys, higher than the nearby ridgeline. Not only this affects the natural landscape but also causes wall effect which directly affects Liu To Village and Mount Haven at the downhill. The government admits that this proposal will inevitably cause visual impact and affect ventilation to the surrounding areas. The approval of this proposal will cause irreversible change to the landscape and ventilation of the nearby residential area.
10. Lacks public consultation violating the procedural justice
The discussion materials of this proposal were submitted to Kwai Tsing District Council five days prior to the regular meeting. There is also a lack of comprehensive information about this rezoning plan. This hinders the citizens to understand the proposal and development project. In the regular meeting of May 2021, Kwai Tsing District Council concluded that the discussion on this proposal was delayed until there is a comprehensive report. However, the report was submitted to the Town Planning Board to apply for the amendment of OZP for this proposal. Moreover, on 2nd July 2021, the residents of Liu To Village were requested to relocate elsewhere without being consulted . It seems the government deliberately concealed the actual site works involved, such as works on the slope, which are likely to exceed the proposed work areas. The government is thus found suspect of violating procedural justice. The public are poorly informed of the development projects and their opinions are disregarded under the current consultation procedures and administrations.
 Town Planning Board. (2021). Draft Tsing Yi Outline Zoning Plan (OZP) No. S/TY/31. Retrieve on 6 Jul 2021 from https://www1.ozp.tpb.gov.hk/plan/ozp_plan_notes/en/S_TY_31_e.pdf
 Liber Research and Greenpeace. (2021). Missing Brownfields – Hong Kong Brownfields Report 2021. Retrieve on 6 Jul 2021 from https://drive.google.com/file/d/1OpwN7b9BccgbaL_7gDKMoFtB03xEDuQb/view
 HK01. (2021). 青衣寮肚村突被納入發展範圍要清拆 區議員憂計劃延伸周邊綠化帶. Retrieve on 7 Jul 2021 from https://www.hk01.com/18%E5%8D%80%E6%96%B0%E8%81%9E/647146/%E9%9D%92%E8%A1%A3%E5%AF%AE%E8%82%9A%E6%9D%91%E7%AA%81%E8%A2%AB%E7%B4%8D%E5%85%A5%E7%99%BC%E5%B1%95%E7%AF%84%E5%9C%8D%E8%A6%81%E6%B8%85%E6%8B%86-%E5%8D%80%E8%AD%B0%E5%93%A1%E6%86%82%E8%A8%88%E5%8A%83%E5%BB%B6%E4%BC%B8%E5%91%A8%E9%82%8A%E7%B6%A0%E5%8C%96%E5%B8%B6 (Chinese only)