Many of the development proposals within the Study will require EIAs. What if an EIA subsequently find that a certain proposal is environmentally unacceptable? Can such a project be cancelled? Otherwise the proponent could argue that the project is already planned and simply take compensatory measures to mitigate the impacts. In fact this has been the case for a number of previous EIA projects. Therefore, from my understanding proposals in this Study are not finalised until all of the relevant EIAs are passed.

The main purpose of this Study is to formulate an up-to-date development strategy for the South East New Territories to guide long-term development of the sub-region. The Study has included broad technical assessments to ascertain the overall acceptability of the strategy. Upon endorsement of the strategy, district plans would be prepared to provide more detailed planning framework to facilitate implementation of relevant proposals. As for specific projects, it would require further investigations and impact assessments by the respective proponent to ascertain project feasibility before proceeding to implementation. Therefore the broad land use proposals in the development strategy cannot be taken as planned projects to avoid scrutiny on the feasibility and environmental aspects.

An example of the above point is the proposal for widening of Hiram's Highway, which is subject to a detailed landscape and visual impact assessment.

A.2

This Study has identified the need to improve the capacity of the section of Hiram's Highway between Ho Chung and Sai Kung Town. It has also recommended further assessments (including EIA) be undertaken to examine the proposal, with environmental sustainability being a major consideration when formulating the options for improving Hiram's Highway.

In dealing with the problem of additional traffic in the area, it is suggested that certain roads be open only to public transportation during holidays.

A.3

Apart from the traffic and transport proposals recommended in the draft strategy, this Study reckons that improvement to the transport capacity is not an ultimate solution to address growing traffic demand of the Study Area. It has recommended close monitoring of the traffic pattern in the area and to instigate further study to recommend the appropriate traffic management measures for the area.

Waste arisings will definitely increase with development of the area. How will future waste arisings be handled? Which refuse transfer station will be used? Or if waste is directly delivered to the SENT Landfill, what is the transportation arrangement?

Most of the waste arisings will be domestic wastes. They will be collected from refuse collection points and then transported directly to the nearby SENT Landfill for disposal. Since the developments in Sai Kung are rather dispersed and of low density, a refuse collection system with transfer stations was not examined in this Study.

As the Study Area is planned to be developed for tourism and recreational purposes, why are there so many housing development proposals, particularly when these developments will have adverse construction and operational impacts? With the associated population increase, nature conservation of the Sai Kung Peninsula will be further threatened.

The Study has recommended the planning vision of enhancing the Study Area into the Leisure Garden of Hong Kong. To this end, the Study has recommended to maintain the currently planned level of residential development, with limited addition (amounting to around 6,600 people) to facilitate rural upgrading as well as the restructuring of the Sai Kung Industrial Area. To enhance nature conservation, the Study has designated the Country and Marine Parks and other areas of ecological interest as "no-go areas" and has recommended a number of conservation actions such as the extension of the Ma On Shan Country Park to cover the Ho Chung Valley woodlands. It also recommends statutory planning and other types of impact mitigation to give due respect to the important terrestrial ecological resources identified in the Study, while designated projects should be subject to the EIA process.

The total inorganic nitrogen content in the Port Shelter area will tend to approach the WQOs limit. How will this problem be solved?

The Phase 2 upgrading of Sai Kung Sewage Treatment Works will include upgrading of treatment level with a view to keeping the total inorganic nitrogen content within the limit. With the upgrading, the treatment works would be able to sustain the 2016 development for SENT. Further development beyond 2016 will be constrained by the total inorganic nitrogen content, subject to the results of the monitoring of the water quality in Port Shelter that has been proposed.

The increased water-based transport will have impact on coral resources in the marine environment.

Coral communities are mostly found in shallow areas (<10m) adjacent to the coastline. For the conservation of coral resources and marine habitat, the present Study recommends the delineation of the coastal area of High Island and its neighbouring islands, which include most areas of coral growth, as a potential Marine Conservation Area. Within the Marine Conservation Area, three non-anchorage points (namely north shore of Bluff Island, Long Kei Wan and west shore of Sharp Island) are proposed to avoid coral damage. Subject to the effectiveness of the above, more non-anchorage points may be designated upon further study. With the above measures, water transport should not have undue impact on the coral resources.

Up to now are there any solid plans or mechanisms to preserve the Tai Long Wan agricultural lands in resisting the encroaching development pressures (Paragraph 3.3.26, Vol. II)?

The current Tai Long Wan Outline Zoning Plan (OZP) has already provided the planning mechanism for development control in the area. Apart from the area set aside for village development to meet small house demand, most of the agricultural land in the area are protected by the "Conservation Area" zoning. Arising from the gazetting of the OZP in early 2000, objections have been received including requests for village developments and those for nature conservation. These objections are being processed by the Town Planning Board and would be submitted together with the OZP to the ExCo for consideration in due course.

It is good to include a bicycle track along Hiram's Highway, but has the buffer planting as proposed along the sides of the Highway taken account of mitigating the possible roadside air pollution impact to cyclists (Paragraph 3.5.14, Vol. II)?

According to our broadbrush assessment, predicted pollutant concentrations on the sensitive receivers along Hiram's Highway are within the Air Quality Objectives (including a receiver with buffer distance of 4m). Thus it is expected that the proposed bicycle track along Hiram's Highway should not be subject to adverse air quality impact. Nevertheless to further ensure the air quality along the bicycle track, mitigation measures like buffer planting should be considered in the project design stage.

For the private historical buildings, is it possible to ensure that their re-development will be compatible with the educational and tourism purposes of the Study Area (Paragraph 3.6.20, Vol. II)?

There is currently no statutory control over the re-development of private historical buildings, unless they are declared monuments or deemed monuments. Under such a context the Study recommends an administrative approach whereby a government or quasi-government agent may take the lead to explore the possibility of redeveloping/converting targeted private historical buildings into viable uses e.g. holiday inns, and to co-ordinate the private owners for its implementation and promotion.

The northermost portion of the Sai Kung Peninsula has been identified as an Area of Concern, since it was excluded from both the SENT and NENT study areas (1.2.2, Appendix B). This Area of Concern nonetheless appears to have been taken into account under the subject study (2.1.5, Vol. I), although no detailed recommendations are contained in the Revised Preliminary Land Use Framework (at Figure 1.2). Sites identified with the potential or need for conservation action would include: Ma On Shan, Mau Ping San Uk fung shui woods, Wong Chuk Yeung, Yung Shue O mangrove and marshes, Cheung Shueng marsh and pond, Tai Tan mangrove, and To Kwa Peng mangrove. I should appreciate it if the proponent would explain how and when these recommended conservation actions, such as land use zoning, SSSI designation and extension of Country Parks would be implemented.

- The northern portion of Sai Kung Peninsula is in fact covered by the North East New Territories Development Strategy endorsed in 1996. The Strategy has recommended conservation as the planning theme for the area, with "Country Park" and "Countryside Conservation Areas". The area is termed the Area of Concern in the present Study, which has proposed to maintain the current conservation planning theme.

- While the Area is outside the study boundary, it has been taken into account in the baseline review, and its potential conservation value is identified. Taking these findings into consideration as well as its close proximity to North East Sai Kung, the Study recommends conservation actions be further considered and undertaken where appropriate, with the identified natural resources as a basis.

- Nevertheless as the Area of Concern is outside the Study Area, the present Study has not proposed specific conservation actions, which is subject to further study.

Would the proponent please confirm the total population for the sub-region (excluding Tseung Kwan O) upon full implementation of the Study will be 103,000 (1.4.7, Vol. I), and not 125,000 (as indicated in the Stage 3 Consultation Digest)?

This Study has estimated the total population in the SENT sub-region (excluding Tseung Kwan O) could reach 103,000 by 2016 and to 125,000 upon full implementation of the Strategy. These estimates provide the relevant input to the various technical investigations, particular on the transport and utility aspects, in assessing the overall sustainability. The actual population growth would require continuous monitoring.

Even so, I remain concerned about the adverse impacts of this planned large increase in population (of about 60% from existing population of 66,000) in the sub-region. Since the SENT sub-region is characterised by extensive ecological important areas, and sensitive and interconnected natural habitats, large increase in population that results in increase in sewage discharge, environmental disturbance and land use demand, may create excessive environmental pressure on the area. It is thus recommended that the population increase in the area be further reduced.

- The conservation value of the SENT sub-region is duly recognised in the Study, which has actually recommended the planning vision of enhancing the area as the Leisure Garden of Hong Kong. To this end, the Study has recommended to maintain the currently planned level of residential development [which amounts to 118,000 population], with limited addition (amounting to around 6,600 people) to facilitate rural upgrading as well as the restructuring of the Sai Kung Industrial Area.

- Broad technical assessments have been undertaken to ascertain the overall acceptability of the strategy, including its environmental and sewerage aspects. To enhance nature conservation, the Study has designated the Country and Marine Parks and other areas of ecological interest as "no-go areas" and has recommended a number of conservation actions such as the extension of the Ma On Shan Country Park to cover the Ho Chung Valley woodlands.

- Taking into consideration the need for rural upgrading/restructuring as well as natural population growth in the Area, further reduction of population increase is not recommended.

Such reduction in population forecast should also help prevent further deterioration of marine water quality in the area, which already has high total inorganic nitrogen (TIN) that has 'not much room for additional loading of TIN' (3.7.19, Vol. I), and 'non-compliance with the WQOs in particular the dissolved oxygen' (3.4.4, Vol. I). In this connection I would suggest consideration be given to upgrading the sewage treatment level of the Sai Kung Sewage Treatment Works to effect nitrogen stripping.

The Phase 2 upgrading of Sai Kung Sewage Treatment Works will include upgrading of treatment level with a view to keeping the total inorganic nitrogen content within the limit. With the upgrading, the treatment works would be able to sustain the 2016 development for SENT. Further development beyond 2016 will be constrained by the total inorganic nitrogen content, subject to the results of the monitoring of the water quality in Port Shelter that has been proposed. The actual population growth in the Study Area should also be closely monitored to provide input to the further assessments on the water quality and treatment facilities.

In addition, relocating sparsely populated villages, such as Pak Lap, Long Ke Wan, Tai Long Wan, Kau Sai Chau and Kiu Tsui Chau, to town fringe areas where connection to trunk sewers are possible, should be explored. This should prove preferable to relying on local solutions (package sewage treatment plants or communal septic tanks).

The Study recognises that most of the remote villages in SENT is relying on individual septic tanks. To improve the situation, it is proposed to provide package sewage treatment plants or communal septic tanks. As for village relocation, it would need to be assessed from the perspective of the current small house policy as it would have territory-wide implications. In the case of SENT (excluding Tseung Kwan O), it is further constrained by the shortage of available government land as the relocation sites. Under such constraints, the provision of package sewage treatment plants or communal septic tanks is considered an acceptable solution and is an improvement to the existing arrangement.

The proposed designation and extension of Country Parks at Tung Lung Chau (Corlett & Ng, 2001) and upper Ho Chung valley are welcomed. I am however concerned that the proposed extension of Ma On Shan Country Park to cover woodlands at Ho Chung will be undermined by 'more extensive recreation uses in lower Ho Chung Valley'. The recreational use could incur loss or degradation of wet agricultural land, woodland and stream habitats, alteration of local hydrological systems, pollution of local waterbodies and disturbance to nearby impacts' (2.5.12, Vol. I).

- The Study recommends to extend Ma On Shan Country Park to enhance protection to the relatively continuous woodlands in upper Ho Chung valley. As the woodland is away from lower valley, it is not envisaged to be unduly affected by development in the latter.

- As for the potential impacts of the proposed recreational uses in lower valley, the Study has highlighted the ecological resources warrant special consideration. These aspects should be fully examined when assessing possible recreation uses in the area in the further planning studies and revision to the current district plans.

Similarly agricultural lands at Ng Fai Tin are found to be worthy of conservation (3.10.8, Vol. II), and yet the area is zoned for "Low Density Housing & Village" use in the Revised Preliminary Land Use Framework at Figure 1.2. Table 2.1 (Vol. I) recommends provision of statutory planning control and establishment of "Conservation Area" (CA) zoning to the agricultural lands at Ng Fai Tin. Elsewhere in the Assessment Report however it states that 'since CA zoning allows draining of wetlands, it may not be the best approach to conserving the areas of interest [at Ng Fai Tin]' (3.10.8, Vol. II). Would the proponent please advise how conservation value of agricultural lands at Ng Fai Tin would be maintained.

- The small-scale plans in the Consultation Digest set out only broad land use proposals to invite comments. These proposals would be refined in the larger-scale plan to guide future developments. For Ng Fai Tin, apart from the existing developed area, the Strategy has incorporated a recognised village development area and the rest would be preserved for landscape conservation.

- To resolve the potential conflict between the identified agricultural land and village development, the Study recommends that future detailed planning to give due respect to the ecological resources identified. In the long term, a more proactive approach would need to be identified.

The potential impacts arising from the proposed education and research facilities at Tai Long Wan (2.5.23, Vol. I) is also of great concern. In particular the education and research centre would likely be exempted from the provisions of the EIA Ordinance. Appendix G (Vol. I) notes that the centre may require an EIA 'if it lies partly or wholly within Country Park or SSSI'. However Tai Long Wan is one of 'the largest Country Park outpocket' (4.4.2.1, Vol. I), and the SSSI there is only 2.3 ha in area (3.3.10, Vol. II).

- The proposed education and research centre at Tai Long Wan is intended to provide educational facilities and enhance public understanding of nature conservation, and Tai Long Wan is considered an appropriate location due to its ecological value.

- To resolve the potential conflict with the natural setting, the Study recommends the centre to be of small scale, to be sited with due regard to the ecological resources in the area and to incorporate the necessary mitigation measures where appropriate.

Further the ACE-EIA Paper mentions 'proposed residential development at Tai Long' (paragraph 6), the impacts of which however have not been assessed.

The residential development in Tai Long is in fact referring to the village type development. Impacts of such developments are assessed in para. 2.5.18 of Vol. I of the Working Paper. Basically these impacts include potential degradation/disturbance of habitats and pollution of waterbodies. Careful detailed planning and design with due regard to ecological resources of the place is recommended (Further elaboration of the recommended mitigation measures are discussed in section 2.6 of Vol. I of the Working Paper).

Tai Long Wan has very high ecological and scenic value (3.3.11, Vol. II) which would not be compatible with even a small-scale development. I would further suggest that village development be limited and in the long run, village housing be relocated to other areas which are less sensitive to development pressure, so that the "Village Type Development" zoning on the Tai Long Wan OZP (S/SK-TLW/1) could be completely removed.

The ecological and scenic value of Tai Long Wan is recognised in the Study, which has identified the area for conservation (Landscape and Conservation Framework of the Public Consultation Digest refers). As for the potential developments in the area, they are being controlled by the current Tai Long Wan Outline Zoning Plan (OZP). Arising from the gazetting of the OZP in early 2000, objections have been received including requests for village developments and those for nature conservation. These objections are being processed by the Town Planning Board and would be submitted together with the OZP to the ExCo for consideration in due course.

An EIA is currently underway for the proposed extension of the golf course on Kau Sai Chau (ESB-064/2000). It should therefore be made abundantly clear, especially to the project proponent of the golf course, that review of this SENT DSR environmental assessment shall not in any way pre-empt the statutory process under the EIAO for the golf course extension.

The main purpose of this Study is to formulate an up-to-date development strategy for the South East New Territories to guide long-term development of the sub-region. The Study has included broad technical assessments to ascertain the overall acceptability of the strategy. As for specific projects (including the Kau Sai Chau golf course), it would require further investigations and impact assessments by the respective proponent to ascertain project feasibility before proceeding to implementation. Therefore the broad land use proposals and their environmental assessments in the development strategy cannot be taken to avoid the statutory process under the EIAO.

The Study identifies highly significant impacts at the SAR level from loss or degradation of streams and agricultural wetlands, and moderately significant impacts at the SAR level from hillfire, and loss or degradation of fung shui woodland and coastal habitats (2.8.8-2.8.13, Vol. I). It further notes that 'co-ordination of an approach to such [cumulative] impacts will require support from the highest levels in Government' (2.8.7, Vol. I). Please would the proponent explain how the cumulative impacts identified would be addressed.

To avoid/mitigate the potential ecological impacts, the Study recommends local planning and other existing mechanisms of impact mitigation to give due respect to the important terrestrial ecological resources identified. Statutory plans are recommended to extend to the entire Study Area, with ecological study suitably conducted. Designated projects should also be subject to the EIA process. In the long term an integrated management approach can be further explored in the Government to bring the resources of different departments together and to enhance their co-ordination.

MARINE ECOLOGY ASSESSMENT
Potential Marine Parks

The planned non-anchoring areas at coastal waters off Long Ke Wan, Sharp Island West and Bluff Island North (Figure 1.2), presumably for coral protection, are supported. Deployment of coral marker buoys should prove more effective in safeguarding the corals from anchor damage (OUCH 2000). In addition, Long Ke Wan, Nine Pin Islands, and much waters in Port Shelter (especially around Sharp Island and Bluff Island) consist of corals of high ecological value (AFCD 2001; McCorry 2001). It is therefore suggested that these areas be identified as Potential Marine Parks.

- Coral communities are mostly found in shallow areas (<10m) adjacent to the coastline. For the conservation of coral resources and marine habitat, the present Study recommends the delineation of the coastal area of High Island and its neighbouring islands, which include most areas of coral growth, as a Marine Conservation Area. Within the Marine Conservation Area, three non-anchorage points (namely north shore of Bluff Island, Long Kei Wan and west shore of Sharp Island) are proposed to avoid coral damage. Subject to the effectiveness of the above, more non-anchorage points may be designated upon further study.

- In addition the Agriculture, Fisheries and Conservation Department has identified a potential Marine Park around Shelter Island and it also has plans to designate the whole of Port Shelter as a Fisheries Protection Area, where there would be a ban on trawling and other restrictions on fishing coupled with a programme of artificial reef deployment.

- It is envisaged that the above measures together will have significant beneficial effects on the marine environment, comparable at least to the designation of an enlarged marine park. As for the protection of corals, a number of ways can be explored, and it is agreed that the deployment of marker buoys is one of the methods.

In this connection, the "Tourist Attraction Node" and the "Water Sports Centre/Base" proposed for Sharp Island West should be removed. Sharp Island West has high coral cover and species richness (McCorry 2001) which would be adversely impacted by the construction and operation of the proposed developments (3.12.24, Vol. II). The removal of these planned nodes is especially important as the proposed developments are likely not subject to the EIA Ordinance (Appendix G).

The Study recognises the value of the coral cover along the west coast of Sharp Island and for that reason has recommended a non-anchoring point there to protect the corals. Regarding the proposed Tourist Attraction Node and Water Sports Centre/Base, we would like to note that Sharp Island West has been developed as a resort before and various parts of it are also occupied by built structures which are mostly dilapidated at present. While some water recreation activities may not be suitable to the area, others are much compatible with it e.g. swimming, scupper diving and small boats sailing. The construction and operation of the proposed development should be subject to further feasibility study and assessments (including environmental assessment) at detailed design stage, though whether it will be subject to the EIAO shall be determined at the project design stage.

Whilst supporting in principle the Potential Marine Park at Shelter Island, it is not clear on what scientific basis the proposed designation is recommended. Moreover the (statutory) protection afforded by the Marine Conservation Area status is also unclear. Please would the proponent explain the use of this novel land use?

The scientific basis of the Potential Marine Park at Shelter Island is detailed in a feasibility study carried out by Agriculture, Fisheries and Conservation Department. As for the Marine Conservation Area, it is intended to highlight the conservation value (especially for corals) of the area, where non-anchorage points are proposed. The Marine Conservation Area is not intended to be statutory but for educational purpose only.

Tourism and Recreation Nodes

Meanwhile the possible conflict of land use between water recreation and Marine Conservation Area is of considerable concern. The Study highlights the potential of water skiing and jet skiing though no specific area has been defined for these activities (8.4.10, Vol. I). In addition, speed ferry service for holiday recreation would be developed, replacing the initially proposed speed ferry service between Metro Town and Sai Kung. Such uses and increase in marine traffic may result in negative impacts on the marine environment, including excessive underwater noise, discharge of sewage, and leakage of oil and other pollutants from the boats.

While the Study recognises the potential conflict of some water recreation and vessel activities and the marine environment, these impacts are not likely to be significant. The feasibility of the proposed speed ferry service for recreation trip would require further investigation and the environmental and conservation aspects should be duly assessed.

In particular, three Chinese White Dolphins recently took residence in Hebe Haven (WWF HK 2000; WWF HK 2001), and many more may migrate to the area in future. Water recreational activities that would be allowed at the "Water Sports Centre/Base" at Hebe Haven would intensify the disturbance on the resident dolphins and should be avoided. Both the dolphins, and Finless Porpoises also found in the area, are vulnerable to excessive underwater noise.

In formulating the proposed Inshore Water Recreation Areas in the Draft Recommended Development Strategy, a number of factors have been taken into account, e.g. existing water recreation areas, and their impacts on traffic, ecology and environment. As for Hebe Haven, it is already a popular water recreation area at present. We note the comment with respect to the recent sightings of the Indo Pacific Humpbacked dolphin near Hebe Haven and would like to point out that this event is recent. If time reveals that the dolphins adopt this area permanently, AFCD will likely provide appropriate protection in the future.

It appears that the initially proposed island hopping routes in Port Shelter and Rocky Harbour, and the Heritage Boat Trail have been abandoned. Whilst this may prevent some potential adverse impacts on the marine environment, it is uncertain how the "Tourist Attraction Nodes" at offshore islands would be serviced. The impacts of such commuting services for tourists have not been assessed.

The island hopping routes and Heritage Boat Trail in Port Shelter and Rocky Harbour are part of the draft Recommended Development Strategy of the present Study (please refer to the Tourism and Recreation Framework in the Public Consultation Digest). The impacts of such boat trips on the marine environment are unlikely to be significant.

Further it is interesting to note that for a number of impacts, mitigation by 'provision of artificial substrates such as bolder reefs that encourage growth of marine life and fish stocks' have been recommended. These include impacts incurred during the construction phase and by increased vessel disturbance (e.g. 2.10.13, 2.10.15, 2.10.24, Vol. I). I should appreciate it if the proponent would advise the scientific justification for the use of artificial reefs in compensation for water quality impacts, disturbance, and loss of benthic organisms.