English version also completed:
1) The proposal document has put focus on the revised layouts and numbers in comparison to the previous version, and present the apparently positive improvement with the adoption of ‘wetland management’ in the scheme. However, there lacks of details on the likely impacts caused by development and the assessment, nor has preventive/mitigating measures been included. Besides, there also needs more details of the methodology and applications of ‘wetland management’ before concluding as ecological enhancement with the scheme
2) We understand that Nam Sang Wai and Lut Chau are in fact part of the same ecological system as with Mai Po, the Deep Bay RAMSAR reserve (of course, birds will only see them as one large piece of wetland). However, part of Nam Sang Wai has been abandoned for some time, as some fish ponds drained or filled and become semi-wetland (condition changes seasonally), consequentially its ecology deteriorates and conservation value lessens. This resulted in reduction of total area of wetland in account. The proposed scheme in fact is going to develop residential housing on this kind of semi-wetlands at the southern part of NSW, which means that these lands will permanently disappear and no chance for rehabilitation. The area of semi-wetlands are not accounted as ‘wetland’, therefore, the document presents that there is ‘no-net-loss’ of wetland. However, it does not mean at all that the semi-wetlands have little ecological value and not worthy for conservation. It may be misleading and shifting focus of the public.
3) The scheme proposes for development of housing on the reed land which has significant importance for bird lives and ecologies - it is found as the largest reed field in Hong Kong’s territory. It should be conserved but not destroyed, and will not be replaceable by re-planting in surrounding of pond sides of the development.
4) The wetlands of NSW have been left continuously unmanaged / abandoned were mainly due to lack of long-term strategic conservation and zoning plan -
which involves ecological assessment and classification of the land, and implement conversation measure accordingly to protect the environment, in contrary to let their ecological value degrade over time and then development takes place and named as ‘sustainable’, or even packaged as ‘enhancement scheme’. NSW, with its similarly significant ecological and environmental importance (in terms of birds’ population and species, and as food supply/habitat for migrating birds), deserves for permanent and highest possible conservation measure – we should consider for possibility of land exchange in order to provide land elsewhere for the development requirement. If it is not possible for whole project, still needs to consider reducing the scale of development with partial land exchange, which will maximize the conservation area and effectiveness. However, the document completely rules out this possibility and shows little commitment to protect our environment.
5) The development scheme will cover almost half of the southern area of NSW, including the area of existing habitat of cormorants - their population ranges from 2000 to as many as 5000, comprising up to 5% of whole populations of the specie in South East Asia (data from Wetland International). There is no other habitat of same scale found in Hong Kong and it highly deserves conservation but not displaced by development.
6) There will be as many as 1400 resident housing and building of 16 floors height in the development scheme, these will be causing noise/light and other human disturbance to bird lives permanently. Besides, roads and bridges for vehicles will intersect with the route migrating birds, the traffic and disturbance may dispel birds from inhabiting, feeding and reproduction in the area. The cumulative impact needs to be considered and minimized, the proposed scheme should not be accepted as it will destroy important ecological elements of Nam Sang Wai.
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