長春社 since 1968
The Conservancy Association
會址 : 香港九龍青山道 476 號百佳商業中心 1 樓 102 室
Add.: Unit 102, 1/F, Park Building, 476 Castle Peak Road, Kowloon, Hong
Kong
電話 Tel.: (852)2728 6781
傳真 Fax.: (852) 2728 5538
31 March 2015
The Secretary
Town Planning Board
E-mail: [email protected]
Dear Sir/Madam,
Re: Comments on the Section 16 Application No. A/NE-KLH/490
The Conservancy Association (CA) OBJECTs to the section 16 application No. A/NE-KLH/490.
Unauthorized excavation in greenbelt
According to the Remarks of Green Belt (GB) zone under the approved Kau Lung Hang Outline Zoning
Plan (OZP) No. S/NE-KLN/11, ‘Any filling of land/pond* or excavation of land, including that to effect a
change of use to any of those specified in Columns 1 and 2 above or the uses or developments always
permitted under the covering Notes (except public works co-ordinated or implemented by Government, and
maintenance, repair or rebuilding works)*, shall not be undertaken or continued on or after the date of the
first publication in the Gazette of the notice of the interim/draft* development permission area plan without
the permission from the Town Planning Board under section 16 of the Town Planning Ordinance.’ There is
no permissions granted by Town Planning Board (TPB) for excavation of land on the application site.
However, excavation of land has been reported within the application site on 18th March 2014 (Figure 1 and
Figure 2).
Referring to Executive Summary of the Section 16 application No. A/NE-KLH/490, ‘The site was
agricultural land until the 1980s and currently does not have any specific use. It does not contain any
valuable flora, being composed mostly of grass land.’ However, the application site was a greenery area
with plenty of trees on 20/6/2013(Figure 3) and the vegetation was removed by December 2013(Figure 4).
This is a typical case of “destroy first, build later” and thus TPB should reject the application to avoid setting
an undesirable precedent.
Lack of sewage impact assessment
In light of clause 2c of TPB guidelines for application for development within green belt zone under Section
16 of TPB, ‘applications for New Territories Exempted Houses with satisfactory sewage disposal facilities
and access arrangements may be approved if the application sites are in close proximity to existing villages
and in keeping with the surrounding uses, and where the development is to meet the demand from indigenous
villagers.’ Besides, in accordance with the clause 7.2 of the approved Kau Lung Hang OZP No.
S/NE-KLN/11,’substantial portion of planning scheme area falls within the upper indirect water gathering
ground so development in this area should be strictly controlled in order to protect the water resources from
being contaminated by wastes and pollutants’. Since the application site locates within the upper indirect
water gathering grounds, detailed sewage impact assessment should be submitted to prove whether the
application has no adverse impacts.
Not in line with the planning intention
One of planning intentions of GB of approved Kau Lung Hang OZP No. S/NE-KLN/11 is that ‘There is a
general presumption against development within this zone’. Large-scale project of establishing 34 small
houses, with a site area of 10261.2 m2, is not in line with the planning intention. It will set an undesirable
precedent and pose adverse cumulative impact to the environment.
Campaign Officer
Leung Tak Ming
Figure 1
Devastated land within the application site (Photo: Designing Hong Kong)
Figure 2 An excavator and devastated land within the application site (Photo: Designing Hong Kong)
Figure 3 Application site is a greenery area with plenty of trees
Figure 4 The vegetation was removed by December 2013