LIM response to offshore LNG Terminal proposed for next to Soko Islands

i May 20th No Comments by

Offshore LNG Terminal proposed for next to Soko Islands.13173243_976686972448834_7041170181981622181_o


Inspection Period: 7 May 2016 – 20 May 2016

Read full proposal via…/re…/profile/latest/esb292/esb292.pdf


Here is the submission that LIM made on the Offshore LNG Terminal proposed for next to Soko Islands which we also posted at

It was disappointing to hear this project being released only a few days after the consultation on Lantau Development closed. It is unfortunate that the Government departments that CLP and their consultants have discussed the project with did not advise the Lantau Development Advisory Committee and have it incorporated in the Lantau Development Proposal. This plan indicates that the water south and west of Lantau Island were to be for creation and not industrial facilities like ship berthing facilities.

We are certainly supportive of Hong Kong’s need to improve air quality so see the potential health and environmental benefits which this project many be able to deliver to Hong Kong through more power being generated from gas instead of coal.

It is pleasing to hear that the proposed LNG project if it proceeds, will be taking into account the proposed though yet to be announced location of the over 700 ha marine park required as part of the EIA requirements for the Integrated Waste Management Facilities (IWMF) near Shek Kwu Chau, and the Soko Marine park which is going through the gazette get process. We hope that marine park will not be designed around the proposed LNG offshore facilities berthing area though rather the marine park boundaries be proposed and gazetted before the LNG facilities are confirmed.

Here are some further comments in no particular order:
– Why could the location for the LNG Berthing and Jetty Facilities not be to the west of the Soko Islands?
– What would be the normal shipping approach taken for the LNG ships coming to and from the facility from international waters? A map showing the routes would be helpful.
– Will the LNG receiving facilities have a exclusion zone for all vessels including recreational fishing boats?
– Could the Double Berth Jetty of the LNG receiving facilities be design to incorporate an artificial reef
– Could some form of closed loop heat exchanging system be used rather than pumping sea water directly through pipes for the re-gasification at the LNG receiving facilities? This would reduce the volume of chemicals required to be added to the sea water.
– While the use of the earlier EIA report undertaken by CLP for the previously proposed land based LNG terminal at the Soko Islands reduces the financial burden on CLP, we are concerned that there have been a significant reduction in the population of the Chinese White dolphin since this time and therefore are concerned that assumptions used in that earlier EIA report my no longer be valid, especially for the dredging for the pipelines.
– Why is there no information provided showing what exists or is planned in the Chinese waters and islands near the proposed project? Surely while outside the direct control of HK authorities it is a very important part of planning the construction and on going operation of the proposed project. Please include similar information like that in Figure 4.1 for a 30-50 km radius around the proposed project site.

Overall our concerns are around the sea portions of this project like the pipelines, berthing facilities and LNG ships. We have less concern with the facilities located at the two power plants.

Living Islands Movement

Submissions on the “Space for All” Consultation Document by LanDAC

i Apr 30th No Comments by


Read LIM’s two Submissions on the “Lantau Development Public Engagement Digest“,
One is a Lantau Wide Response (in PDF or Text Version) and
the other is focused on Mui Wo (in PDF or Text Version).

Lantau Wide Response

Lantau Wide Response

Mui Wo Focused Response

Mui Wo Focused Response










There were many other well considered submissions made by others including:

plus articles in the SCMP including:

Here is some background on the topic.  The Lantau Development Advisory Committee (LanDAC) was formed in January 2014 to be:

“mainly responsible for advising the Government on opportunities brought by the planning and major infrastructure in Lantau and on various aspects of sustainable development and conservation of the island, with a view to fully capitalising on its locational advantages and seizing development opportunities to foster the long term socio-economic development of Hong Kong. “
(according to

In January 2016 LanDAC released the “Lantau Development Public Engagement Digest” which was open for comments until 30 April 2016.

Living Islands Movement (LIM) consulted with its members and reviewed the LanDAC website and associated documents, plus attended a number of forums and hosted Ching-min CHAN from the Development Bureau at our AGM on 9 April.


Full Text version of Lantau Wide Response

The Secretariat,
Lantau Development Advisory Committee
17/F., East Wing, Central Government Offices,
2 Tim Mei Avenue, Tamar, Hong Kong

By e-mail:

29 April 2016

Public response to
Lantau Development Public Engagement Digest “Space for All”
Lantau Wide Response

The Living Islands Movement (LIM) is an organisation dedicated to creating a liveable Lantau for all and has members across Hong Kong, with a significant number living on Lantau Island. LIM has consulted with its members and reviewed the LanDAC website and associated documents.

We conclude that the consultation document and process to date has not been well planned and certainly does not represent a visionary document fitting for “Asia’s World City”. The digest is very disappointing as it does not deliver in terms of “Balancing and enhancing development and conservation, with a view to developing Lantau into a smart and low-carbon community for living, work, business, leisure and study”.

There have been many concerns expressed and interesting proposals suggested during the preparation of this submission. However, we have chosen to highlight 10 key items only, on the assumption that there will be many other meaningful opportunities for the community to work with Government on the overall planning and detailed design of development on and near Lantau Island. Our 10 key items are:

  1.  The ‘Space for All’ plan was devised by LanDAC, an advisory Committee appointed by the Development Secretary and constituted of an overwhelming majority of developers.  Only one member of LanDAC is recognisable as a conservationist.  The remit of LanDAC was to produce a plan which balanced the need for development with the need for conservation.  This did not happen.  The Government now needs to appoint expert conservationists to sit in equal numbers with developers on this Committee if they are to stand any chance of gaining credibility with the public about their intentions on conservation.
  2.  Public consultation has been too quick and too thin.  No public consultation has been held in Mui Wo, one of the key areas that will potentially be impacted most by the plans.
  3.  No needs-based study has been conducted or presented to support the Government’s claims about the need to build housing for a million people.  No needs-based study has been conducted or presented concerning making Lantau a logistics hub for the PRD.
  4.  No Strategic Environmental Study has been conducted for the plans, to ascertain what cumulative environmental and conservation consequences may result from implementation of its various elements.
  5.  The ‘Space for All’ plan is not compliant with Hong Kong’s obligations under the International Biodiversity Convention.  Hong Kong should be committed to protecting areas of high biodiversity value, such as Lantau Island, not causing significant damage to valuable eco-systems and habitats, which this plan will inevitably do.
  6.  The plan has NO suggestions about enhancing conservation as it claims.  The only suggestions it has about conservation are to increase access, including for large tourist numbers, which will require building more infrastructure and which will significantly diminish conservation.
  7.  The Government’s own concept plan from 2007 suggested the South of Lantau would be largely untouched and reserved for recreation and leisure.  Yet, ‘Space for All’ is littered with suggestions for ‘medium’ sized projects on the south of Lantau to attract large numbers of tourists to ‘theme park’ type attractions.
  8.  Despite claiming that the South of Lantau would be protected, the Government has not ensured any statutory protection for the ‘Coastal Protection Areas’ along the South Lantau coast.  This has resulted in significant illegal landfilling and fly-tipping.  The Government needs to ensure that statutory protection is applied and enforced forthwith.
  9.  The majority of Hong Kong’s public enjoy Lantau as a green lung, somewhere to escape the fumes and congestion of high density housing and urban living.  The current peace and tranquility of Lantau is exactly why people like to go there.  If this is destroyed then Lantau becomes like anywhere else in Hong Kong.
  10.  We implore the Government not to proceed with a funicular railway up Sunset Peak.  There is already a cable car to Ngong Ping, close to the summit of Lantau Peak, we should leave the other major peak untouched.  It already has good accessibility by way of the Lantau Trail and is enjoyed by many for its peace, tranquility and unspoilt views.

LIM supports the following comment made by Ruy Barretto in his submission:

“LanDAC should not assume that their proposals are in the overall interest of Hong Kong when they are not. The Plan is focused on private interests which will commercialize the countryside. The Digest is based on a series of assumptions and subjective opinion. This is not a valid basis for spending billions of dollars of public money and destroying the environment.”

LIM strongly urges the Government and LanDAC to publish clear steps to show how any Blueprint will be developed. Those steps should include meetings and workshops with environmental, business, tourist, cultural and social interest groups so that individuals and professional bodies can work together with the Government to facilitate “Balancing and enhancing development and conservation, with a view to developing Lantau into a smart and low-carbon community for living, work, business, leisure and study”.

Living Islands Movement


Full Text version of Mui Wo Focused Response

The Secretariat,
Lantau Development Advisory Committee
17/F., East Wing, Central Government Offices,
2 Tim Mei Avenue, Tamar, Hong Kong

By e-mail:

29 April 2016

Public response to
Lantau Development Public Engagement Digest “Space for All”
Mui Wo Response (see separate Lantau Wide Response)

The Living Islands Movement (LIM) is an organisation dedicated to creating a liveable Lantau for all and has members across Hong Kong, with a significant number living on Lantau Island. LIM has consulted with its members and reviewed the LanDAC website and associated documents.

This submission focuses on the Planning Issues for Mui Wo and can be read separately to LIM’s other submission titled “Lantau Wide Response”.

Mui Wo is pivotal to the Lantau Development plan since it is the historic gateway to South Lantau and the crossroads between the South Lantau, ELM and North Lantau sectors of LANDAC’s schema.

Space for All mentions numerous ideas under different categories:

  1. General – Utilizing abandoned agricultural land, fish ponds and under-utilized land (page 9) [1]
  2. Tourism – “Mui Wo historic rural area”, one of four scenic areas with unique characteristics (page 8)
  3. Recreation – “an adventure park (e.g. zip-line, hillside slide, paintball/war games, etc.), an aqua park (e.g. Wibit, fly-boarding), mountain biking, Segway riding etc.” (page 19)
  4. Transport Infrastructure – “possible road and Rail Links from/to the ELM and to the north Lantau shore” (pages 16 and 17)
  5. Conservation: No specific mention, but clearly 2 implies conservation of most of the Mui Wo basin to the West of the Ferry Pier and Old Town areas. Also, LIM’s vision for Mui Wo includes a wetland park in the valuable area in the South West of the basin.

Unfortunately, no overview is provided on how these diverse ideas might fit together to form a viable, holistic plan for the area. Many of them are potentially in conflict, and there are no specifics on location, land requirements and sequencing.

Recent experience is that government has found it difficult to implement even a small part of the “Mui Wo Facelift Plan” first launched in 2007. Reasons are:

  • It has proved difficult to reconcile conflicting land use interests and coordinate efficiently among the many government departments involved. For example free parking on Mui Wo waterfront near Ferry Pier for large commercial vehicles, versus pubic demand for recreation space, waterfront cafes and restaurants etc.
  • Slow progress on implementing the Mui Wo Sewage Improvement Scheme. For example, Phase II has been in planning since 2009 but has still not received final approval. Phase I commenced later than expected and had the knock-on effect of delaying the start of Stage I of the Mui Wo Face Lift by some 18 months.
  • Unwillingness to include conservation and recreation objectives under Land Resumption for “public purposes”. For example, heritage trails and cycling trails in Mui Wo basin area, first proposed in 2007/2008, have been postponed indefinitely because in all cases “private land” is involved.

LIM believes that a new approach is needed to Mui Wo development. The main objectives are to:

  • Accelerate the Mui Wo Face Lift through to completion of phase III in a 5 year time-frame.
  • Roll out the sewage scheme to the whole of the Mui Wo basin more urgently, to facilitate upgrading of the village environments and to avoid impeding other developments.
  • Undertake a new planning exercise to see what else can be done without destroying the essential rural character of the area. This may include updating the existing Mui Wo Fringe Outline Zoning Plan and extending it to include un-zoned areas such as Silvermine Beach, Wang Tong Village and Tung Wan Tau villages and environs.

We look forward to participating in workshops and forums held in Mui Wo, with a wide representation of stakeholders and Government departments, to position Mui Wo as a pilot showcasing how in reality Hong Kong can achieve “Balancing and enhancing development and conservation, with a view to developing Lantau into a smart and low-carbon community for living, work, business, leisure and study”.

Living Islands Movement

[1] We don’t understand this statement. The reality is that Mui Wo basin has only about 100 hectares of flat land. Most is already taken with Village (“Small House”) development and agriculture (eco-farming). There is however a wetland of high ecological value to the South West.

Successful Application for Judicial Review of dumping in Pui O Wetland

i Feb 14th No Comments by

We just realised that we forgot to let you know about some potentially good news for the Wetland in Pui O (and also potentially other wetlands in HK).

The Judicial Review application, challenging the Government’s decision to allow dumping of construction waste on the pristine wetlands of Pui O has been accepted.

LIM is delighted that stage one of a Judicial Review, challenging the Government’s decision to allow dumping of construction waste on the pristine wetlands of Pui O, was won at the High Court on January 20. The Department of Justice, representing the Government, fought hard to have the application for Judicial Review dismissed on four grounds. Presiding judge, Justice Au, ruled that the Government’s argument, that the Director for Environmental Protection, does not have any discretion when giving ‘acknowledgements’ for dumping to occur, had not been successfully made. He further dismissed the Government’s contention that the Judicial Review had been applied for outside of the prescribed time limits and that a judicial review was not necessary because the ‘acknowledgements’ for dumping had either run out or were just about to.

This means the application for Judicial Review was successful and a full hearing at the High Court will now be held on September 27th at 10am to resolve the issue. You can join the hearing so make the date in your calendar. We’ll keep you updated on further developments and how to register to attend the hearing.

Here is one of the newspaper reports on the application –

Letter to Public Accounts Committee asking to rescind funding for incinerator

i Jan 10th 1 Comment by

Living Islands Movement (LIM) sent a letter to the Chairman of the Public Accounts Committee (PAC), in relation to the recent report from the Director of Audit, Report 65 ( which highlights that the Environmental Protection Department (EPD) has been misleading HK on the true situation with our landfills and that EPD have been promoting waste management strategies that are extremely overpriced and not fitting for a modern global city.

In short LIM strongly urge the Public Accounts Committee to recommend that funding for the landfill extensions and incinerator projects are rescinded or at least frozen until a full review is undertaken and the need for all components is reassessed based on correct information.

Read a copy of the LIM letter to PAC.

Public Accounts Committee - Hon Abraham SHEK 20160107

Government audit of Hong Kong’s waste reduction efforts makes clear who is to blame for our growing mountain of rubbish

i Dec 3rd No Comments by

An informative piece by Tom Yam published by the SCMP (1 Dec 2015) that builds on the Audit Commission report titled “Government’s efforts in managing municipal solid waste“.

Hong Kong’s waste problem: a stinking trail of missed targets, data errors and misdirected efforts

Tom Yam says a government audit of Hong Kong’s waste reduction efforts makes clear who is to blame for our growing mountain of rubbish.

Screen Shot 2015-12-05 at 5.58.14 PM

If an organisation misses targets, mangles statistics, mismanages capital assets, underestimates costs, undertakes trifling projects and underperforms in a critical task year after year, will it survive?

The answer is a resounding “yes” if it is the Environmental Protection Department.

The department’s data, used to manage ongoing programmes, is rubbish (pun intended)

The Audit Commission recently issued a report on the government’s management of the garbage, officially known as municipal solid waste, which Hong Kong produced over the decade to 2015. The Environmental Protection Department is responsible for waste management and has an annual budget of HK$2.05 billion to do the job.

By every measure, including the department’s own as set out in its Policy Framework for the Management of Municipal Solid Waste (2005-2014), and the Hong Kong Blueprint for Sustainable Use of Resources (2013-2022), it fell short.

Key performance indicators for waste management have all deteriorated. Per capita waste disposed daily increased from 1.27kg in 2011 to 1.35kg in 2014. Waste recovered and recycled dropped from 49 per cent in 2009 to 37 per cent in 2013. Food waste increased from 3,227 tonnes per day in 2004 to 3,648 tonnes in 2013.

READ MORE: What a waste: Hong Kong government ‘set to miss targets’ as people dump more rubbish

The landfill in Tseung Kwan O. As of 2013, 63 per cent of Hong Kong’s waste was still dumped in landfills. Photo: SCMP Pictures

The policy framework set a target of disposing of 25 per cent of waste in landfills by 2014. As of 2013, 63 per cent was still dumped in landfills.

The department’s data, used to manage ongoing programmes, is rubbish (pun intended). The Audit Commission cites a litany of statistical errors. The amount of waste recovered for recycling was inflated because the department included waste imported for processing. Its forecast of a 50 per cent drop in food waste from school lunches was overstated because only 12 per cent of students ate lunch in school. It could produce no quantifiable data to explain its changing assumptions about the serviceable life of the landfills. It now claims that all landfills will be full by 2018. The Audit Commission believes they should last some years beyond 2018.

The department priced phrase 1 of the Organic Waste Treatment Facilities, to recycle mainly food waste, at HK$489 million in 2010. But because it omitted or significantly underestimated the cost of some components, the cost surged to HK$1.589 billion in 2014.

READ MORE: Waste not, want not: The ‘food angels’ collecting goodies we’re about to throw out to cook for Hong Kong’s underprivileged

The producer responsibility scheme for plastic bags has been rolled out, albeit behind schedule. But the scheme has yet to be implemented for five other products, including glass bottles. Photo: Jonathan Wong

Target dates for rolling out the producer responsibility scheme for six products, based on the “polluter pays” principle, have not been met. Only the first two phases of the plastic shopping bag levy have been implemented, in 2009 and 2015, six to eight years behind target. The scheme has yet to be implemented for the other five products – waste electrical and electronic equipment, vehicle tyres, glass bottles, packaging materials and rechargeable batteries.

Only four of the 12 government departments have signed up to the Food Wise Hong Kong Campaign, which promotes reduction of food waste, two years after its launch.

With great fanfare, the department did launch a series of waste reduction, recovery and recycling initiatives. Their impact, however, has been inconsequential. Net reduction of plastic shopping bags disposed of in landfills in 2009-2013 was 11,544 tonnes, or an infinitesimal amount of total waste disposed.

READ MORE: Cycle of waste: City’s recycling industry needs must be addressed by Hong Kong government

… Article Continues though


… Summary of Article …

The audit report describes a mismanaged organisation that lacks coordination with other government departments, produces inaccurate information and statistics, and engages in inconsequential efforts to tackle waste reduction and recycling. It cannot effectively manage ongoing programmes, resulting in missed targets and deteriorating performance.

In the private sector, a chief executive accountable for such rotten results would have been fired. Yet the previous environment secretary, Edward Yau Tang-wah, is now director of the Chief Executive’s Office. The current one, Wong Kam-sing, is this week attending the UN climate change conference in Paris. The Environmental Protection Department’s director, Anissa Wong Sean-yee, has been in her job since 2006. Despite the audit report, all three are likely to keep their highly paid jobs in Hong Kong’s non-accountable government.

Tom Yam is a Hong Kong-based management consultant. He holds a doctorate in electrical engineering and an MBA from the Wharton School of the University of Pennsylvania

Disappointed the Court of Final Appeal dismissed the technical case against the incinerator

i Nov 26th No Comments by

Living Islands Movement (LIM) was very disappointed in the decision of the Court of Final Appeal in dismissing the case against the incinerator earlier today.  We now await the judge’s written decision.

This week’s Audit Commission report ( which shows the Government have provided misleading information to the public about waste management and recycling is relevant to today’s decision because it was partly this misinformation that provided the basis upon which the EPD (Environmental Protection Department) sought to justify the need for an incinerator in the first place. LIM will work with other interested parties to further examine the Audit Commission’s findings and explore options for further legal or other challenges.

We continue to urge that the Government pause, review and then move forward with measures which would see Hong Kong adopt waste management practices fit for the 21st century in line with their goals to make Hong Kong Asia’s first city. One such example is that put to the Town Planning Board in 2013 (

Lantau is Hong Kong’s Most Beautiful Island and Deserves Protection 香港最美島嶼 — 大嶼山愛守護 勿摧

i Nov 9th No Comments by

Martin Williams ( has created and posted in youtube a very compelling video on the beauty of Lantau.

As part of the game plan to save Lantau from irresponsible and unsustainable development and to preserve its natural environment, this type of video should be widely distributed to raise Hong Kong citizens’ awareness on this unique green asset.

Please share the video with your friends and colleagues.

Hong Kong’s plan to reduce its waste enters the realm of fantasy

i Sep 4th No Comments by

Tom Yam says the government’s plan to reduce our waste through charging – while doing little to encourage recovery and recycling – is based on wishful thinking and won’t be realised

Tom Yam


Here’s a tip for delegates coming to Hong Kong for an international conference on solid waste: skip our environment secretary’s keynote address. Go to Disneyland instead. You’ll be immersed in Fantasyland either way, but you’ll have more fun with Mickey Mouse than Wong Kam-sing.

Wong is expected to recite his “Hong Kong Blueprint for Sustainable Use of Resources 2013-2022”. The part on waste management is as fantastical as Space Mountain, but minus the thrills. To reduce Hong Kong’s Waste Mountain, the Environment Bureau’s goal is to cut by 40 per cent the amount of solid waste disposed of per capita, from 1.27kg per day in 2011 to 0.8kg in 2022 (no matter that the figure in fact increased to 1.33kg in 2013). The bureau insists this is achievable through charging us for the solid waste we produce, along with public education, and cites the success of South Korea and Taipei in shrinking their waste mountains.

But the bureau is wishing upon a star. A waste-reduction policy based on reality, rather than wishful thinking, has to follow an inescapable equation: waste disposed is equal to waste generated, minus waste recovered for recycling. Waste charging can reduce the amount of waste generated. But equally essential is increasing the amount of waste recovered and recycled. After introducing waste charging, South Korea reduced the waste it generated by 23 per cent, and increased the waste it recovered from 24 per cent to 60 per cent. Taipei reduced the waste it generated by 62 per cent, and increased the waste it recycled to 60 per cent. The combined effect of generating less garbage and recovering more of it for recycling is necessary in reducing the amount of waste that needs disposing of.

A further reality that the bureau wilfully ignores is that waste recovery and recycling is impossible without a mandatory, systematic programme of waste separation. Recyclable waste, such as paper, metal, glass and plastic, needs to be handled separately from waste that ends up in landfills or the incinerator. Such a programme cannot be enforced without legislation. Taiwan has introduced such laws: a Waste Disposal Act and a Resource Recycling Act, which mandate comprehensive waste separation and recycling.

Similarly, South Korea introduced a Waste Control Act and an Act on Promotion of Saving and Recycling of Waste. It takes political will to push through such a statutory framework.

Key to recovering more waste is a recycling industry that can profitably process such waste into marketable products like recycled paper, glassware, plastic items and building materials. To support its recycling industry, Taiwan has an annual recycling fund of NT$6 billion (HK$1.5 billion ). It has become a leading developer of recycling technology. In South Korea, a government-sponsored Korea Environmental Corporation provides financial assistance to the recycling industry, resulting in a substantial increase in the number of recycling companies in the country.

Hong Kong’s pitiable recycling industry does not have the scale or infrastructure to process recovered waste into marketable products. For starters, 93 per cent of recovered waste is exported for sale, mostly to the mainland. In 2003, the government designated an EcoPark for a high-tech, high-value-added recycling industry. Yet the industry remains stuck at the lowest level of operations: collection, recovery and export of waste paper, metal, plastic, etc, activities with low economic value.

Relying on exporting also exposes the industry to external vagaries. During the global financial crisis in 2008, for instance, the purchase price of waste paper in Hong Kong plummeted from HK$2,000 to HK$700 per tonne. In 2013, when mainland authorities tightened regulations for importing recovered plastics, 100,000 tonnes of plastic waste piled up at collection points.

Without serious and sustained separation of waste to increase the waste recovered, the amount of recyclables is simply insufficient to support the development of a recycling industry. Relying on export, the industry will dwindle as waste exporting options continue to decrease, limiting the amount of recyclable waste that exporters want to recover profitably.

The government has made no serious effort to create an indigenous recycling industry. A one-off HK$1 billion fund proposed to support recycling companies essentially only subsidises local companies to recover more waste for export. HK$1 billion sounds like a lot but it’s measly compared to the HK$19 billion budgeted for building an incinerator, HK$10 billion for expanding landfills, and HK$8 billion for a sludge treatment facility. In 2011-2012, the budget dedicated to education, publicity and advertisement of recycling was only HK$24 million. The allocation of funding reveals the priority: building waste-disposal capacity, not recycling.

Scattered recycling pilot projects are being tried in some housing estates but none have resulted in a territory-wide programme. The tri-colour recycling bins on the streets collect only 700 tonnes of recyclable waste a year, a mere fraction of the waste generated in Hong Kong. Yet the bureau claims it will increase the rate of recovery from 37 per cent of waste generated in 2013 to 55 per cent by 2022.

While the government looks to waste charging in reducing the waste generated, it ignores the other side of the equation: waste separation mandated by legislation and the creation of a viable recycling industry. Yet without these essential components, it aspires to achieve in seven years from now what Taipei took more than a decade to accomplish. There’s a Disney attraction analogous to that aspiration; it’s called The Mad Hatter’s Tea Party.

Tom Yam is a Hong Kong-based management consultant. He holds a doctorate in electrical engineering and an MBA from the Wharton School of the University of Pennsylvania

Paper sent to attendees at the International Conference on Solid Waster 2015: Knowledge Transfer for Sustainable Resource Management

Time is running out fast for Hong Kong’s water buffalo

i Aug 18th No Comments by

The protected wetlands of Pui O on Lantau are being ruined by illegal construction waste dumping and, as usual, civil servants are turning a blind eye, as villagers eye the profits of development, writes Angharad Hampshire



Credit : SCMP 16 Aug 2015

Jean Leung Siu-wah is known in south Lantau as the “buffalo whisperer”. Slight and in her 60s, she moves with grace among the grey, mud-spattered beasts that amble gently through the island’s green, open spaces.

Leung has lived on Lantau for more than three decades. For six years, she has been feeding and taking care of the buffalo around Pui O. Every day, she walks through the wetlands, delivering fresh banana and sweet potato leaves and fruit to the animals.

One buffalo in particular receives the royal treatment. Ngau Ngau, a 13-year-old male with trademark majestic crescent-shaped horns, gets the pick of the crop. He huffs affectionately through his nose as Leung slaps his rump.

Ngau Ngau was once a regular visitor to Leung’s garden, in Shap Long Kau Tsuen, on the Chi Ma Wan peninsula, where he would raid her vegetable patch. Leung became fond of him, despite his antics. One day, Ngau Ngau turned up with a broken leg. Leung sought a vet’s advice and was told that if she cared for Ngau Ngau for a couple of weeks, the animal would probably survive. Thanks to Leung’s continued support, he thrives, despite having a shortened hind leg.

The verdant pastures and wetlands around Pui O make it an ideal home for Hong Kong’s largest herds of water buffalo. However, development is likely to see them vanish as the green lung deflates.

“These buffalo will be gone in 10 years,” says Leung, sadly, as she strokes Ngau Ngau’s hide. “The government is not doing enough to protect them, nor are the villagers.”

Ngau Ngau happily chomps his way through a bucket of banana leaves while two other buffalo mosey up to Leung, to grab a mouthful of fruit. They are all blissfully unaware that the ground on which they walk is at the centre of an escalating row, and that their future hangs in the balance.

handout_07aug15_fe_buff4_copy_2Buffalo were introduced to Hong Kong as working animals.

Over the past eight months, construction waste has been dumped over four separate plots in the wetlands of Pui O, land designated as a “coastal protection area”. Dumping of waste on such land is prohibited, as is nearly all construction. However, the government’s interpretation of the law means it’s nigh on impossible to stop the rubble rising.

“The villagers want to protect their development rights but this area here is meant to be protected,” says Leung, indicating the fields that lie in the open valley behind Pui O beach. “However, villagers don’t think that way. They shoo the cattle off the land and then concrete it. Then it’s of no use to the buffalo and no longer worth protecting.”

THE WATER BUFFALO, Bubalus bubalis, is not indigenous to Hong Kong. Members of the species were brought here in the mid-1900s to work on paddy fields. Their power and waterproof skin make them perfect for ploughing alluvial coastal plains to cultivate rice. As Hong Kong developed rapidly in the 70s and 80s, and shifted towards manufacturing, farming declined. The buffalo were no longer needed and were gradually abandoned to fend for themselves.

The remaining buffalo are now feral and, as such, have no official owners, although the Agriculture, Fisheries and Conservation Department is responsible for managing them.

“According to a territory-wide population survey on stray bovines conducted by the department in 2013, there were around 120 feral buffalo in Hong Kong,” says Esther To Man-wai, the department’s senior veterinary officer. She is in charge of the department’s Stray Cattle and Buffalo Management Plan and its Cattle Management Team. “Most of them favour wetlands and dwell mainly in lowland areas.”

Eighty-three of these animals live on Lantau; the rest can be found around Yuen Long, in the New Territories.

Lantau buffalo activists want cameras along roads to deter speeding

Water buffalo weigh between 400kg and a ton and stand up to 1.6 metres high. They live for about 25 years and are generally social animals, staying in family groups. One bull will form a herd, with between one and three cows and their calves. Bulls that are not successful in forming a family herd will congregate in a bachelor herd. Each year, other males compete with the alpha animal in a herd to become the dominant bull and take the group. On Lantau, there are three breeding herds and three bachelor herds.

“Even though they may not be indigenous, I am in favour of keeping the buffalo as part of the biodiversity of Hong Kong,” says Howard Wong Kai-hay, one of To’s predecessors and now the executive director of the School of Veterinary Medicine at City University. “They have been here for quite a while now and are part of the flora and fauna.

“Obviously, when you’re in government, you’ve got people who want them there and people who don’t want them there and you’re in the middle. So, what we thought was, ‘Let’s develop a policy where we try and pay heed to the desires of both parties in a sense that we don’t think we should remove them completely from Hong Kong but we don’t think they should reproduce out of control either.’

“The idea was to manage the population at the level that existed in 2011 and not let it grow further while not culling them for no reason, either. So, we set up a cattle team to try to manage the behaviour, to decrease the amount of trouble the buffalo and cattle cause to people who don’t want to see them. Sai Kung Buffalo Watch [the name is correct even though Sai Kung has no water buffalo, only feral cattle] and the Lantau Buffalo Association were also involved with volunteers and we all worked together.”

Jean Leung Siu-wah, aka the buffalo whisperer.

Wong thinks the government’s handling of the buffalo and other bovids in Hong Kong has been exemplary: “Government rarely comes up with policies that are reasonable and appeal to both sides. Too often we have a knee-jerk reaction – trying to eliminate the problem rather than manage it. People manage populations of wild animals all over the world, why should Hong Kong be any different? As [we had] a reasonable response, it got a lot of support.”

Ho Loy, chairwoman of the Lantau Buffalo Association, which was set up in 2004, explains how the beasts, which need a wetland habitat in order to wallow to cool off and escape insects, provide a unique service.

“Water buffalo are unique in that they can restore the condition of abandoned farmland,” says Ho. “If you just leave abandoned farmland it collects garbage and plants that don’t provide biodiversity. Buffalo restore water to the environment and the way they churn up the land with their hooves and horns encourages plants and wildlife that provide a water purification and filtration aspect.

“If you look at all the rural environments in Hong Kong, abandoned farmland is always between the natural water source and the village area. The buffalo provide an eco buffer zone. This protects the source of water for humans and also cleans any polluted water released from the villages. The habitat also creates a breeding ground for thousands and thousands of other species. They extend an area of wetland by up to five times. No other animal on the planet can do that; this is why we call them wetland angels.”

A study by the global conservatin group WWF has shown that when you put water buffalo into wetlands, the biodiversity of the creatures found there increases exponentially. It has been estimated that freshwater wetlands hold more than 40 per cent of all the world’s species and 12 per cent of all animal species.

Ho points to the canals formed by the buffalo’s tramping and churning. A fish leaps from one furrow, flips in the air and plunges back between plump-leaved wetland plants.

“Without the buffalo’s presence, wetland areas start to dry out and the special ecology with various amphibian species and beautiful birds goes into decline,” she says. “Pui O is the most important water buffalo habitat in all of Hong Kong.”

Less than 50 metres from where Ho stands, construction waste is piling up on that “most important habitat”.

In 2001, prior to a project to upgrade electrical cables from Pui O to Cheung Chau, power company CLP Power conducted an environmental-impact study of the habitat “between the Pui O villages and the Pui O beach, including the Pui O Marsh and Taro Bed” – basically, where the water buffalo live. It concluded that the land was of “high ecological value” and found a total of 52 species living in the wetland, “which is high compared with other wetlands in Hong Kong”.

“[The CLP Power study] is the only comprehensive environmental-impact study of the area that can be found on record,” says Martin Lerigo, an executive committee member of the Living Islands Movement, a group dedicated to the sustainable environment of Hong Kong’s outlying islands, with a focus on Lantau. “It documents in detail all of the wildlife and plant life here. It found species of plants, amphibians and birds that are rare to Hong Kong and semi-rare internationally. It provides substantive documentation that the wetlands are of high biodiversity and ecological value and that land adjacent to them would be the same if left undisturbed for 15 years.


Construction waste dumped in Pui O.

“As the study was done in 2001, 14 years ago, it is likely that these adjacent areas are now, in fact, of high biodiversity and ecological value. Another study must be done to establish whether this is the case or not.”

The Living Islands Movement has been working alongside others to prevent further dumping on Pui O’s wetlands, a project that has required both tenacity and patience.

The Environmental Protection Department says the CLP study is out of date and that the department does not need to consider it when “acknowledging” and giving the go-ahead for the dumping of rubble on the wetlands. The Living Islands Movement has asked for a new study to be conducted. With bureaucratic alacrity, the department says that, in accordance with the Environmental Impact Assessment Ordinance, an assessment can only be carried out for “a defined project” and, as the dumping is piecemeal, it does not qualify.

People who want the wetlands, with their near-unique flora and fauna, to be conserved feel trapped in a catch-22 situation. The environmental protection and conservation departments will neither give consideration to the out-of-date assessment nor sanction a new one. It raises the question of how the departments responsible for environmental protection and conservation can fulfil their responsibilities when they refuse to assess whether a piece of land needs protecting.

The wetlands in Pui O lie within land designated as a coastal protection area in an outline zoning plan drawn up by the Town Planning Board for south Lantau. According to the board, “This zone is intended to conserve, protect and retain the natural coastlines and the sensitive coastal natural environment, including attractive geological features, physical landform or area of high landscape, scenic or ecological value, with a minimum of built development. It is also intended to safeguard the beaches and their immediate hinterland and to prevent haphazard ribbon development along the south Lantau coast. In general, only developments that are needed to support the conservation of the existing natural landscape or scenic quality of the area or are essential infrastructure projects with overriding public interest may be permitted.”

The plan expressly forbids filling and dumping within the coastal protection area. However, the government’s interpretation of the law means the South Lantau outline zoning plan is unenforceable because no enforcement controls, in the form of a document called a “development permission area”, were added to the original plan.

When this anomaly, which affected a number of outline zoning plans across Hong Kong that lacked DPAs, was addressed in 1991, the rectification wasn’t made retrospective. Also, for reasons best known to the board, when it amended the Town Planning Ordinance and the outline zone planning process in 1991, it was decreed that a new plan would not be allowed where one already existed.

In other words, south Lantau’s outline zoning plan, which is unenforceable, cannot be replaced with a plan that is enforceable. In effect, the outline zoning plan might as well not exist.

Consequently, the director of the Environmental Protection Department, Anissa Wong Sean-yee, who has discretion within the Waste Disposal Ordinance to either “acknowledge” or decline applications to dump rubble, has been able to approve four applications so far. There are more than 20 further such applications in the pipeline. If they are all allowed, the Pui O wetlands will disappear forever.

The Living Islands Movement and others have spent six months corresponding with the department while the rubble has grown into large, unsightly heaps. The department and other relevant government departments have given one reason after another as to why they can’t stop the dumping. Eventually, local objectors felt they had no other option but to take the matter to judicial review.


Ho Loy, chairwoman of the Lantau Buffalo Association.

“For a judicial review, you can’t simply say you don’t like the government’s decision,” says Lerigo. “A judicial review deals with whether the decision breaches the constitution and whether it involves administrative flaws, namely illegality, irrationality or procedural impropriety. The applicant for the judicial review, a local resident, is challenging this decision on the grounds that it breaches the outline zoning plan and the intention of the law that the outline zoning plan should be enforced. In addition, the Waste Disposal Ordinance implies discretion on the part of the [environment] director and she should have applied her discretion to prevent dumping of rubble on an area of high ecological and biodiversity value, exactly the areas that Hong Kong has committed to protect under its obligations as signatories to the Convention on Biological Diversity.

“She should also have used her discretion on the issue of vehicular access, as the plots of land that have been dumped on were accessed by dump trucks crossing private and government land without permission. Plus, there is one plot that was fly-tipped on a year ago. The [environmental protection department] asked for the rubble that was fly-tipped to be removed by the landowner, who just left it there. The landowner later applied to fill the same plot and was given the go-ahead by the [department]. This is tantamount to the [department] condoning fly-tipping: a criminal act, which, ironically, is policed by the [department].”

In response to requests for comment for this article, a departmental press officer will say only, “In view of the pending [judicial review], we do not consider it appropriate to comment or provide an interview on this matter.”

Those who condone the dumping say the landowners in question have gained the required permission from the department and that if people are so bothered about saving the buffalo, they should donate their gardens to the animals. It is understandable why landowners want to despoil agricultural land. If, at a later date, the land is rezoned for housing – a distinct possibility if the whole area becomes nothing more than a pile of rubble – then they can build. Village houses on Lantau sell for somewhere in the region of HK$15 million each.

“It’s a difficult conundrum because most people find it understandable why indigenous villagers feel they have a right to develop their own land,” says Lerigo. “It’s worth noting, however, that the vast majority of the patchwork of privately owned lots which make up the wetlands do not belong to indigenous villagers but to property development companies, registered in interesting places like the British Virgin Islands and Liberia. “The majority of indigenous villages still have an affinity for the place in which they grew up; the wetlands and the buffalo are part of their heritage.”

“Foreigners say we don’t like the buffalo but they misunderstand us,” says Ho Chun-fai, who is a representative of Sai Wan Village and has lived his whole life in Pui O. “Actually, many of us love the buffalo but we also have our own interests. We also want a balance between nature and people but the foreigners ignore our needs and concerns and they only think about the buffalo … and this creates a conflict.”

That conflict is often stoked by misunderstanding, he says. “A woman was pushed off the path by fighting buffalo and injured. We are trying to widen the path to make it safer. As soon as we started, a complaint was raised about the dumping, so we were told to stop by the [environmental protection department]. But actually, it’s not dumping of construction waste; it’s a mixture of earth and a bit of rubble just to make the path a safe width.

“This is the kind of thing that really annoys villagers. The government is stopping us making it a safer place for us to live. We need the government to act as a middle man in this conflict and to explain our rights.”

Foreigners say we don’t like the buffalo but they misunderstand us

Ho Fong-tim is another indigenous villager who is fed up with the attitude of “complaining foreigners”, and he, too, is looking to the authorities for a solution. “The government is not doing anything to help local people. The government needs to offer us some solutions. For example, it could offer to exchange the land. If that happened then the government could keep the fields and we could use the other land. The government actually knows about the problem but it isn’t doing anything about it.”

Lerigo agrees that the onus is on the authorities, “in particular those government departments responsible for the environment, conservation, land and planning, [which should] come up with a solution that recognises land rights of indigenous villagers … and the need to protect ever-dwindling areas of outstanding beauty, which we need to protect for the next generation of Hongkongers. There are options like land swaps, rezoning or extension of existing village zones, which, whilst difficult, can be achieved if the political will is there.”

“The government has a Development Bureau and a Lantau Development Advisory Committee,” says Ho Loy. “So, the government has the manpower and the resources to do it. We have educated the government about why we treasure this land and why we believe in sustainable development. We’d like our government to demonstrate that it cares about our environment and not just about money.”

Says Ho Chun-fai: “We need to be able to find a solution that suits all parties – the local people, the government, the foreigners and the buffalo.”

The focus is now on the Environmental Protection Department; will it live up to its name? If not, what will happen to Lantau’s water buffalo?

“I would certainly hope that [the conservation department’s] policy is one that would allow the continued presence of these buffalo elsewhere in Hong Kong, if that is the last resort,” says Wong. “One option … is the wetlands near Mai Po. There are already a few buffalo there and they are of tremendous benefit to the biodiversity, with their stomping and eating. The [department’s] wetland park [in northern Tin Shui Wai] could also take a few. There are some still in Kam Tin, of course, but development is rampant there, as well.

“Of course, it is best to leave them in Lantau.”

IMG_0175 IMG_0176

Credit : SCMP 16 Aug 2015

LIM Response to Proposal for Relaxation of Traffic Restrictions on South Lantau

i Jul 22nd 1 Comment by

Following the invitation by the Transport Department to comment on their Proposal for Relaxation of Traffic Restrictions on South Lantau the LIM committee have prepared the following response, in consultation with the community, which opposes the TD proposals.

Response to TD re Lantau Roads by Living Islands Movement pg 1 Response to TD re Lantau Roads by Living Islands Movement pg 1 chi


The below Response letter contents can also be viewed as a PDF document in English or in Chinese.

21 July 2015

Dear Commissioner for Transport,

Review of Closed Road Arrangements in South Lantau and Proposals for Relaxation

Thank you for the opportunity to comment on your Paper IDC TTC 33/2015 (the “Paper”) and the proposals contained therein. Living Islands Movement (LIM) has a strong interest in this matter. We have consulted and obtained views of members and discussed the issue at length in committee meetings.

One major concern is that many groups have different understanding of the meaning of the stated objectives of “promoting Tourism and other development”. These should have been better defined and articulated in the brief. But in general, it is considered that large scale Tourism is not suitable for South Lantau, and that other economic development is already proceeding apace in the form of residential housing of various types and projects such as the Mui Wo and Tai O Facelifts. Our view is that additional stimulus is not needed at this particular time.

We reflect these views in more detail below, but would summarize our opinion as follows:

  • LIM is opposed to any further relaxation of arrangements for Private Vehicles from external sources to access the South Lantau Road at this time in view of the burgeoning demand for permanent LCRPs from local residents, which is set to accelerate further in the near term.
  • On the other hand, we strongly support provision of improved and additional Public Transport, including enhanced bus services, more licensed taxis, more frequent ferry services and other initiatives to improve individual and small group visitor access to South Lantau for recreational and other purposes.

Our views are based on a wider analysis of South Lantau’s transport needs, which we believe should match the actual and planned state of development of the area.

Traffic issues arising from rapid pace of Residential Housing development

As the Paper correctly points out, the current planning intention for South Lantau is for it to be preserved…….”for nature conservation and sustainable recreational and visitor uses”. It was also understood that there was to be a limited amount of low density residential development.

However, a rapid pace of issuance of building licenses for Village Houses, several high-end residential developments along the South Lantau Road and construction of about 650 new Home Ownership Scheme flats in Mui Wo are leading to a surge in demand for permanent Lantau Closed Road Permits (“LCRPs”) from the rising residential population of the South Lantau area. This growth in internal demand is set to continue for several more years as these projects are completed and occupied. The extreme pressure on public space for parking in Mui Wo and elsewhere, (even at the current level of vehicle ownership), is well known and on the current trajectory may only become materially worse over the next 2-3 years.

In this context, it is in LIM’s view inadvisable to begin opening the South Lantau Road to external private users at this time. Although the initial proposal is modest in scale, the direction of policy risks raising expectations of further opening to unsustainable levels. Instead, LIM recommends that the situation be reassessed when the Mui Wo and Tai O Face Lift are much further advanced, so that the actual impact on traffic and parking from all these developments can be properly assessed.

Issues arising from organized tourism to South Lantau

The Revised Lantau Concept Plan of 2007 also pointed out that main opportunity for South Lantau was as a destination for recreation (hiking, cycling, watersports etc.) and eco-tourism. The area is not considered suitable for large scale, mass tourist development. However, as the Paper mentions, there are two “themed” tourist destinations in the area, namely the Ngong Ping Monastery and Tai O Village. Both appear to be operating at near full capacity and need little further stimulus.

Therefore, we do not see the need to increase the number of organized coach parties accessing the area. Indeed, the heavy flow of return bus and coach traffic on the South Lantau Road at weekends and holidays is regarded as dangerous and environmentally damaging by the residents of affected areas such as Shui Hau and Tong Fuk Villages.

On the other hand, alternative transport arrangements, such as extending the MTR Cable Car service to Tai O and enhancing the ferry service between Tung Chung pier and Tai O could help to manage the flow of tourists accessing these destinations, and may permit additional growth in a sustainable manner. In particular, we think it desirable to encourage the Cable Cars to be used more fully in both directions, to alleviate some of the environmental pressure from heavy road transport.

Facilitating individual access to South Lantau for Recreational Activities

LIM views the growing use of the South Lantau area for recreational purposes by individuals and small groups of visitors, including many “locals” from other parts of Hong Kong, as a positive development and in-line with the overall vision for the sustainable development of the area.

However, visitors and residents alike complain of the difficulties of moving around the area via public transport. The shortage of licensed taxis is acute, and the bus service, although now enhanced at weekends, is still inadequate, leading to long queues and extensive waiting times. The ferry service to/from Central appears to be adequate at present, but will soon be under pressure from the expected continued growth of both resident commuting and visitor arrivals.

Overall, we believe the emphasis of the current discussion should be switched away from relaxing restrictions on private vehicles entering South Lantau and towards upgrading significantly Public Transport options for visitors and residents.

LIM would also like to see additional public transport options explored, such as introducing a mini-bus service and double-decker buses. Another idea would be to set up a private/public transport interchange at Tung Chung.

Safety and policing issues

Many of our members are very concerned about the safety issues that will arise from the relaxation measures. It is well known that the South Lantau Road and connecting roads are narrow and winding and unsuitable for large vehicles. Lantau roads are also dangerous for drivers who are unfamiliar with the conditions here.

The Police have already pointed out that they do not have the resources to either a) adequately monitor for dangerous driving and speeding vehicles or b) effectively ensure that vehicles entering the South Lantau area comply with the requirement to display a LCRP.

On point a) LIM and others have repeatedly asked for more stringent speed limits and traffic calming measures on key sections of the South Lantau Road system, especially those passing through villages, as yet to no avail. We believe strongly that this issue needs to be revisited before any further relaxation of access measures are introduced.

On point b), there is already anecdotal evidence of significant numbers of vehicles entering the area without a permit. Further, the Paper does not give any detail of how usage of the new day permits will be monitored and enforced. In our view, the introduction of electronic systems for monitoring and controlling the access to the South Lantau area from the Tung Chung gateway is long overdue.

According to the Paper there are already 4,000 permanent LCRPs in issuance, yet there only 350 parking places in the area. Of course it is unknown how many private parking spaces exist, but it is clear that so-called informal, often illegal, parking in and around the villages and Mui Wo in particular is an increasing problem. This has potential to cause social disturbance if not carefully managed. It is impractical for the Police to act in this regard since there are no alternative parking facilities. As mentioned above, this situation is almost certain to deteriorate further in the next few years.


While LIM supports measures to enhance transport arrangements for the South Lantau area, we believe that this should be in-line with the stated development goals of the Revised Concept Plan for Lantau. The greater emphasis should be on enhancing public transport facilities for the rapidly growing resident population and visitors seeking recreational and eco-tourist opportunities in South Lantau.

  1. The proposal to increase the number of coach permits to 50 per day is not justified by the data, except perhaps for certain public holidays and events. Therefore LIM does not support this proposal.
  2. The proposal to introduce private car access for non-residents is not supported by LIM because it does not address the demand for wider public access to South Lantau at weekends, and raises expectations of further increases in future. This demand should be met by enhancing public transport instead.

We recommend that the South Lantau communities be consulted further, perhaps through a public forum, on how best to improve the Tourist experience in ways that do not damage the environment and quality of life here.

Dr Merrin Pearse
Chairman of Living Islands Movement