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Hong Kong Institute of Landscape Architects (HKILA) in collaboration with WWF-Hong Kong
Response to the Draft San Tin Technopole Outline Zoning Plan (OZP)

HKILA recognizes the significance of the San Tin Technopole (STT) development that aligns with the National 14th Five-Year Plan and the strategic positioning of regional developments. It is because of that and the rich environmental resources in the site and its immediate surroundings the proposal must also demonstrate alignment with the national policy on ecological civilization to the highest standard. We offer the following comments and recommendation to the proposal.
While we support the overall strategies covered in the Northern Metropolis Development Strategy Report and the Northern Metropolis Action Agenda 2023 including the creation of a Wetland Park Conservation Parks System (WPCs), and acknowledge the minor adjustment to the development area after public engagement exercises to avoid encroachment into the Ramsar Site, we remain concerned that the current proposal for the San Tin Technopole would result in a direct loss of about 89 hectares of wetland with “moderate” to “high” ecological values , as well as direct and indirect impacts to Deep Bay wetlands and the associated wildlife as identified in the Environment Impact Assessment (EIA) report.
The Northern Metropolis, including San Tin Technopole, is in low-lying land that is under significant threat from the inevitable rise in sea levels due to climate change. The situation will be worsened by the large amount of filling of existing wetland and increased run-off from the developments. Climate resilience and flood attenuation should be fully addressed in the development proposal. Under the Kunming-Montreal Global Biodiversity Framework (KMGBF) that China is a signatory and the Biodiversity Strategy and Action Plan (BSAP) developed by the AFCD of the HKSARG, the proposal must also demonstrate how the goals and objectives of the above are being upheld.
We emphasize that priority given to ecological and green development is one of the guiding principles stipulated in the Greater Bay Area outline development plan, and San Tin offers the opportunity to create a technology hub out of this unique ecological and cultural context. To realize the above and to ensure the success of the development HKILA has established a platform of experts from Shenzhen and Hong Kong to exchange and to formulate guiding principles for the development of the Northern Metropolis, and have been collaborating with WWF-Hong Kong to prepare enhancement to the proposal based on the following recommendations.

1. Enhancing the habitat connectivity at the northwest corner of STT

The northwest corner of STT situated at Hop Shing Wai creates a wildlife movement bottleneck in the Deep Bay Wetland landscape, with the remaining wetland being between the highly urbanized Futian District of Shenzhen in the north and the future developments in the south, posing negative impacts on birds and terrestrial wildlife. We recommend expanding the currently proposed 20m non-building area (NBA) as “eco-interface” and to incorporate an approximately 12.7 hectares of multifunctional green landscape space that connect to the future Sam Po Shue Wetland Conservation Park (SPS WCP) to add approximately 200m to the wildlife corridor by reducing a small portion of the area currently zoned with building height restrictions of +15mPD and +35mPD.

2. Improving the wildlife corridor for terrestrial mammals near Lok Ma Chau Boundary Control Point (LMC BCP)

We recommend enhancing the design to incorporate an “eco-aqueduct” to connect the Sam Po Shue area and near Lok Ma Chau Loop of approximately 570m long and 10m wide, with sunken road underneath for the section, to enhance the wildlife corridor for terrestrial mammals especially the viability of the Eurasian Otters that are endangered species with tiny local population. This integration of landscape design and highway system that cater for endangered species would set a world-class example of endangered wildlife conservation and firmly placed Hong Kong at the forefront of eco-civilization in the regions. 

3. Adopting Nature-based Solutions (NbS) in STT to increase flood resilience

To alleviate flood risk in the area including the flooding blackspot Shek Wu Wai, we recommend retaining, restoring, and enhancing the existing watercourses as far as practicable and to connect them to the existing San Tin Eastern Main Drainage Channel (STEMDC) and San Tin Western Main Drainage Channel (STWMDC) that is proposed to be retained by the government. These open watercourses provide additional capacity to the surface runoff from the STT developments on top of environmental and ecological functions. We recommend also to incorporate river parks alongside the major rivers that are designed to be floodable with a wide riparian zone that could allow a diversity of recreational activities and to accommodate excessive water during extreme weather. A successful example of similar river park is the Bishan-Ang Mo Kio Park in Singapore, renowned as an urban NbS integrating people and nature.
Convert selected existing fishponds into flood retention lakes as part of the open space network. Compared to underground stormwater storage facilities, ground-level flood retention lakes provide a more cost-effective mean to flood attenuation and provide also benefits of multiple eco-services.

4. Enhancing the flight corridor for birds

The EIA report proposes a 70m wide flight corridor for the breeding ardeids at Mai Po Lung Egretry by designated non-build area (NBA) in the I&T zone and open space along the STWMDC. However immediately abutting the flight corridor are zoned to allow building developments with a maximum permitted height of +105mPD, creating a narrow slit. To enhance the flight corridor to serve the purpose we recommend expanding the NBA to cover the small patch of land between adjoining roads and the STWDC to enlarge the open space network and as part of the river parks recommended above.
The EIA report proposes also to allow a 300m wide flight corridor near the Lok Ma Chau Boundary Control Point (LMC BCP) and a stringent building height control nearby. However, beyond the strip of land adjacent to the flight corridor with a maximum building height of +35mPD, the building height restriction immediately next to it (Area 19A) dramatically rise to +130mPD, which diminishes the effect of the flight corridor and contradictory to the statement in the EIA report that “building structures with stepping heights will also be implemented within the proposed development… low-rise development near the 300m flight corridor, and gradually increase away from the corridor”. It is also incompatible with the surrounding rural landscape in the adjoining Lok Ma Chau Village and its associated environment.
We recommend reducing the permitted building height and adopting a stepped building profile within Area 19A from +35mPD to +75mPD form north to south that would on one hand uphold the effectiveness of the flight corridor and on the other hand provide a coherent building height profile to the developments in the west, the mountainous landscape in the east, and the SPS WCP in the north. We believe the minor reduction to the total gross floor area resulted from the above recommendations can be easily compensated in the less ecologically sensitive areas such as areas near Poon Uk Tsuen, Chau Tau and Saddle Pass.

5. Promoting agricultural landscape and diverse landscape typologies of open space 

According to the EIA report, all agricultural land (10.56ha) within the Technopole area will be lost permanently. From the draft STT OZP, no agricultural zoning is reserved. This is an irreversible loss of an invaluable landscape feature and cultural heritage element from the once rural area. All wildlife dependent on these agricultural lands will also be directly affected. The EIA report also estimates that 56,350 number of trees (87% of all existing trees) will be affected by the proposed developments, and a substantial and irreversible loss of landscape resources.
We recommend preserving the farmland in Shek Wu Wai area that partly overlaps with Area 7 of the draft STT OZP, and incorporating that into the proposed Cultural and Recreational Complex as an agro-park with recreational farming facilities. It aligns with the proposed land use that facilitate leisure and recreation, therapeutic, and education purposes. The agro-park also contributes also to the promotion of food security, self-sufficiency, and urban biodiversity. Culturally farmland has also been an important part of the history, culture and landscape of the northern New Territories. The location of this agro-park would be close to the remaining villages in Shek Wu Wai and San Tin, as such it will be coherent and compatible with the rural environment. It would also help to soften the sharp interface between these villages and the urbanised residential areas nearby, fostering urban rural integration.
Furthermore, vast amount of compensatory tree planting is proposed for the loss of greenery due to the developments, a diversity of landscape typology should be facilitated, whether within or outside site. We agree with the direction given in the EIA report (LVIA section) that vegetation density, ecological value and recreation of woodland habitats should be considered in compensatory planting. Under the threat of climate change and the unique landscape context, we recommend establishing urban forest or mini-forest on top of urban greenery in consideration of their carbon draw-down and biodiversity functions.
Given the contexts and aspirations of this project, we propose a minimum of 30% at-grade landscape and open-space should be required within the I&T zone, which would be able to accommodate all of the above recommendations including the multifunctional green landscape space at Hop Sing Wai, the eco-aqueduct between Sam Po Shue and Lok Ma Chau, flood retention lakes, the watercourses and river parks, urban forest and productive landscape. We believe that climate-positive and nature-positive design is the key to the success of the STT development in realizing a “new international I&T city” and a “new community for quality, healthy and green living”. HKILA is committed to support and contribute to the developments and look forward to further liaison with the government and stakeholders.

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