2.1       Proposed Development

2.1.1        The subject proposed development Joint User Complex and Wholesale Fish Market is located in Tuen Mun Area 44 as illustrated in Figure 2.1. It is bounded to the north by a future local open space presently used as a temporary car park, to the east by Castle Peak Bay typhoon shelter, to the south by a future lorry park and to the west by Wu Shan Road. The site is mostly zoned “G/IC” (Government, Institution or Community use) and slightly encroached onto the "O" (Open Space) zone on the draft Tuen Mun Outline Zoning Plan (OZP). Figure 2.12 shows the draft Tuen Mun OZP No. S/TM/16. Container trucks, lorries and private vehicles park along the Wu Tai Circuit and inside the site during night time. It may be noted that the location of the proposed WFM is slightly different from the one shown in the study. The reason being that the Tuen Mun Provisional District Board decided on May 4, 1999 that the whole complex in Area 44 should be shifted northward by 20 metres, thereby taking it further away from Yuet Wu Villa. Such a shift is likely to reduce any noise or odour nuisance to the residents of Yuet Wu Villa.

2.1.2        The purpose of constructing these government facilities in this complex is to provide sufficient space for fish wholesaling activities, a marine park management office, a marine refuse collection point, a refuse collection point and public toilet. A much needed and conveniently located community hall facility for a rapidly expanding population is also provided. If the re-provisioning of the wholesale fish market facilities are not provided in the near future, the existing sub-standard temporary market in Area 27, with its deteriorating wooden structure and lack of loading and parking areas, will continue to cause environmental nuisance to the neighbourhood. Figure 2.23 shows the location of the existing CPFM and its surrounding environment.

2.1.3        Concerned District Board members and the great majority of the residents have urged for the early provision of the proposed community hall as the existing community hall facilities are too distant for the residents of Area 44. To better utilise this fish market site, the community hall is included. A permanent spectator stand for the annual Dragon Boat Race is also incorporated into the proposed development along with landscaped decks.

2.1.4        The joint-user complex originally incorporated a possible library which is included in the EIA study brief. Leisure and Cultural Services Department (LCSD) however, have reservations on the suitability of this site and currently do not support the inclusion. The provision allowed for the public library is therefore reserved for other possible community uses. EPD have confirmed that the exclusion of the library or substitution by a building of similar size and nature, having no greater environmental impact than the currently designed library will not affect the validity of this EIA study and its findings. This clarification will apply throughout the EIA report in references to other possible community uses.

2.1.5        The subject project is to provide a permanent, combined government complex for the Agriculture, Fisheries and Conservation Department (AFCD), the Home Affairs Department (HAD) and the Marine Department (MD) in conjunction with the Food & Environmental Hygiene Department (FEHD) and the Leisure & Cultural Services Department (LCSD). The proposed facilities are shown in Table 2.1. The initial sketch layout plans of the proposed preliminary development of the site are shown in Figures 2.34 to 2.67.

Table 2.1         Details of the Proposed Facilities

Proposed Facilities


Operational Requirements

Population of accommodation

Wholesale Marine Fish Market


5000 sq.m. (GFA)

(including parking for 40 lorries)

440 persons

Community Hall


1000 sq.m. (GFA)

500 persons

Other Possible Community Uses

Yet to be identified

3500 sq.m. (GFA)

400 persons

Refuse Collection Point (RCP) / Marine Refuse Collection Point (MRCP)



800 sq.m. (GFA)

10 persons

Marine Park Management Office


200 sq.m. (GFA)

10 persons

Spectator Stand


Roof of wholesale fish market

1000 persons

Public Toilet





2.1.6        The construction of the proposed WFM complex is anticipated to last for 26 months. It is estimated that 9 months will be required for foundation construction and 17 months for superstructure construction. A tentative programme for the construction of the proposed WFM complex is shown in Figure 2.8.

2.1.7        The site is already formed, it is level, there is no planned basement and therefore site preparatory works will be minimal with the exception of piling works in the immediate vicinity of the existing seawall. The construction of large diameter bore piles shall be employed for the foundation construction. In view of the building type and location, the 1st to 4th level structure is envisaged to be of simple reinforced concrete column and beam construction on piled foundations.

2.1.8        The operation period of the proposed facilities is shown in Table 2.2.  The information is provided by relevant Government Departments.

Table 2.2         Operation Period of Proposed Facilities

Proposed facilities

Operation Period

Wholesale Fish Market

Market opening hours:

3:00am – 5:00pm (daily)

Auction and Wholesale operations:

3:00am – 6:30am

Transfer of live seafood and boxed fish

7:00am – 2:30pm

Community Hall

Monday to Saturday:

9:00am – 1:00pm, 2:00pm – 10:00pm


9:00am – 1:00pm, 2:00pm – 5:00pm

#Public Holiday:

9:00am – 1:00pm, 2:00pm – 5:00pm

 # except the first three days of the Lunar New Year

Other Possible

Community Uses

Normal office hours

Marine Park Management Office


9:00am – 5:00pm


9:00am – 1:00pm

Closed on Sunday & Public Holiday

Spectator Stand

All days :

8:00am - 10:00pm

Marine RCP & RCP

8:00am – 6:00pm (Marine RCP)

7:00am – 8:00pm (RCP)

Public Toilet

24 hours


2.1.9        Based on observations of the existing fish market at Area 27, various activities are anticipated in the proposed WFM. Wholesale chilled fish operations in the early hours of the morning will involve the berthing of fishing vessels and the unloading of fish into the WFM by the use of hoists. The fish will then be sorted and weighed in the sorting area. Noise source is largely generated from loading and unloading from buckets and trolleys and also from the dragging of buckets of the ground. After sorting and weighing the fishes will be passed to the auctioning area and auctioned without the use of a public address system. Sold fishes will then be loaded to the fish traders’ containers and taken to the lorries for transport. The nominal design capacity for the fish market is 7900t per annum. (current throughput is approximately 6200t per annum  or 17t per day)

2.1.10    In addition to chilled fish auction operations (from 3:00am to 6:30am), the WFM also caters for the unloading from vessels and the loading on vehicles of fish  (already boxed in ice) and live seafood during other hours (7:00am to 2:30pm). AFCD anticipate that boxed fish sales will gradually increase, currently 410 kilograms/day (0.41t/day), whilst the throughput of live seafood is around 660kilograms/day (0.66t/day). In both cases, the operations associated with this throughput are relatively simple and clean when compared to the sorting and auctioning of fish during night time wholesale operations.

2.1.11    According to the adopted Tuen Mun New Town Area 44 Layout Plan No. L/TM44/2, the area to the immediate northwest of the Wholesale Fish Market (WFM) site has been reserved for the development of a promenade and a district open space. To its southeast will be a goods vehicle park, a promenade and a possible hotel development. However, since there are no definite development programmes for these planned developments, it is anticipated that there will not be any major projects to be constructed and operated at the same time as the WFM.


2.2             Background and History of the Project

2.2.1        The Castle Peak Wholesale Marine Fish Market (CPFM) was originally established at Lo Shu Chau, Castle Peak Bay in 1946 by the Fish Marketing Organisation (FMO) under the Marine Fish Marketing Ordinance, Cap 291.  CPFM is one of the major FMO fish markets in Hong Kong and the largest in the New Territories.  The market is essential for providing orderly fish marketing services for the fishing fleet based in Tuen Mun and for maintaining an uninterrupted supply of fresh marine fish to the population of Western New Territories.

2.2.2        Through the normal planning process and the development of Tuen Mun Town, the CPFM was required to be moved to an alternative location. In September 1973, a temporary site of around 2500 sq.m. in Tuen Mun Area 27 was allocated.  The CPFM was temporarily relocated in late 1974.

2.2.3        The existing CPFM operates in a deteriorating, sub-standard, single storey temporary structure built 29 years ago, without suitable measures to control noise and odour emission from the market operations. The building area is inadequate to effectively manage activities necessary for the efficient operation of a modern fish market. Due to the lack of loading and parking areas for the fish trading activities in CPFM, considerable environmental nuisance is imposed on nearby residents in the Sam Shing Estate and Hanford Garden. At present, lorries for transportation of fish are parked on both sides of Sam Shing Street (the street between the fish market and the Sam Shing Estate) for loading and unloading operations in early mornings. This does not only cause noise and odour nuisance to nearby residents but also create certain amount of congestion in the morning until the lorries leave. Moreover, poor drainage system, rubbish left behind (Figure 2.9) and spillage from fish loading on public roads encourage the development of persistent odour from the market operation. Due to a lack of space and the need to maintain the fish wholesaling operations, the present building cannot be improved and relocation to a purpose designed building is necessary. A suitable permanent location for the fish market is urgently required.

2.2.4        In October 1978, the Tuen Mun New Town Master Landscape Plan was approved by the then Development Progress Conference (DPC), and suggested the fish market be in Area 44.  The subject site was zoned “Government, Institution or Community” (GI/C) on the draft Tuen Mun Outline Zoning Plan (OZP) (no. LTM/2) gazetted on 29.7.1983. The site remains zoned as “G/IC” on the draft Tuen Mun OZP No. S/TM/16 currently in force.

2.2.5        Under the Tuen Mun New Town Are 44 Layout Plan (No. LTM2/44/1L), approved by the then Development Progress Committee on 12.3.1987, the subject site was zoned “Government” and annotated “Site for a Combined Wholesale Vegetable Fresh Water Fish and FMO Wholesale Marine Crustacean Market.” The Site is zoned “Government” annotated “Site for a Wholesale Fish Market (including Joint Uses of Community Hall, Refuse Collection Point, Marine Refuse Point & Public Toilet” on the latest Layout Plan No. L/TM44/2 approved by the committee on Planning and Land Development on 10.8.1998.

2.2.6        The Tuen Mun OZP No. S/TM/5 was gazetted on 30 October 1987 under section 7 of the Town Planning Ordinance to rezone the site now occupied by Yuet Wu Villa from “Industrial” to “Residential (Group A)”.  At this time, the whole length of the waterfront was earmarked for a combined wholesale vegetable, fresh water fish and FMO crustacean market.  At that time the possible nuisance to future residents had been considered and the following measures were proposed :

·        The planning brief for Yuet Wu Villa has specified that the south-eastern corner of the proposed development be reserved for non-domestic use and the disposition, elevation and orientation of the residential blocks should be designed so as to help to mitigate the development constraint.

·        the provision of a ‘local open space’ as buffer zone between the proposed residences and the proposed market.

·        The adoption of suitable noise mitigation measures when designing the new fish market as well as proper management of future operations.

No objection to the OZP was received during the exhibition period.


2.2.7        The Tuen Mun District Board (TMDB) discussed relocation of the Wholesale Marine Fish Market (WMFM) in early 1996. At ensuing DB meetings, Planning Department and AFCD briefed members on why Area 44 was selected as the preferred site after careful consideration of alternative sites in the district. TMDB endorsed the plan in April 1997.

2.2.8        However, some local residents, mainly those of Yuet Wu Villa, together with some TMPDB members, raised objections to the TMPDB and the Legislative Council Complaints Division. They are concerned that the construction of WMFM  in Area 44 would cause odour nuisances, public hygiene problems and noise problems during the operation of the market in the early morning. They requested the Government to conduct another search to identify an alternative site for the WMFM.

2.2.9        In view of the concerns and requests, Government departments carried out a site search for the possible relocation of the wholesale fish market at Area 44 to other areas of Tuen Mun.  A number of alternative relocation sites were considered, based on the following criteria :

(a)    Zoning : a suitable relocation site is preferably of compatible zoning so that rezoning is not required.

(b)   Site Area and Location : the minimum site area for the proposed wholesale fish market is 7,800m2 and must be a waterfront site with sufficient berthing area.

(c)    Timing/Land availability: site preferably made available as soon as possible.

(d)   Sites must be suitable for purpose, safe and to meet the operational needs of the fishermen.  In particular, the fishermen expressed that areas protected by the Castle Peak Typhoon Shelter would be preferred.

The above requirements must be met before any environmental considerations are studied. Figure 2.10 shows the location of the potential sites studied.


2.2.10    The Government assessed the feasibility of building the WMFM in alternative sites, including Area 38, Area 27, Area 16, Area 40, and the Siu Lam Typhoon Shelter site. The results of assessment indicated that considerable constraints exist in alternative sites and they are not suitable for WMFM development. To address the concerns of residents of Yuet Wu Villa, it was suggested that the proposed WMFM be shifted northward by 20 metres to take it further away from Yuet Wu Villa but without getting too close to the LPG storage due north of the proposed development.

2.2.11    The TMPDB, at its meeting on 4 May 1999, discussed the relocation plan and endorsed by a majority vote to advise the Government that the design work for the composite government development in Area 44 (with the public library and the community hall retained as joint users and the original site be shifted northward by 20 metres) would be taken further up to completion of the EIA study.

2.2.12    The site review findings together with TMPDB’s decision were reported back to the concerned Legislative Council members via the Legislative Council Complaints Division.  No adverse comment on either the findings of the site search or TMPDB’s decision were later received.

2.2.13    The site in Area 44 has now been moved 20m to the North as proposed, and the design of the fish market has orientated the WMFM facilities at the furthest point from Yuet Wu Villa to provide the maximum buffer possible.  The EIA assessment is conducted in detail for this site only.


2.3             Scenarios With or Without the Proposed Development

2.3.1        Without the Proposed Development: The existing land uses along the seawall are mainly open area, temporary car parks and industrial buildings. No landscaping of the open area is provided. During night time, container trucks, lorries and private vehicles park along the Wu Shan Road and Wu Tai Circuit and within the subject site. Garbage, empty oil drums and bottles are discarded at the proposed site (Figure 2.911). The neighbourhood is currently affected by environmental impacts associated with these activities, such as noise and vehicular emission from vehicles parked along the street as well as waste disposal problem due to free-tipping at the site. Photographs showing the surrounding environment of the subject site were taken and shown in Figures 2.102a & 2.102b. The nearest library and community centre to the residents in the vicinity of the subject site are located in Butterfly Estate. As the area is already densely populated, the community facilities are inadequate to serve the large population. On the other hand, the environmental conditions of the existing temporary FMO CPFM will continue to deteriorate and the associated impacts caused to Area 27 will persist.

2.3.2        With the Proposed Development: The proposed development will improve the shortage of community facilities at Area 44. The joint user complex provides a community hall, a spectator stand and other possible community uses which are beneficial provisions to all the nearby residents. Proper permanent provision of facilities for viewing the dragon boats is also provided. With the landscape garden on the terrace, the visual environment along the seawall in the vicinity will be greatly improved. The operation of FMO CPFM can be better organised and the environmental problems can be eliminated through proper planning and considered design of the proposed wholesale fish market. Possible environmental impacts such as odour and noise can be readily taken care of with the provision of the necessary mitigation measures. On the other hand, the environmental nuisance caused by the operation of the existing temporary FMO CPFM at Area 27 can be relieved, bringing obvious environmental benefits to nearby sensitive receivers. It also has an additional benefit of eliminating the uncontrolled environmental problems caused by the on-street parking and free-tipping at the site.