Living Lamma’s response to the Director of Environmental Protection on the Environmental Impact Assessment for the Baroque on Lamma as part of the consultation process.
Report Reference 0116093 – ESB229/2011
The Baroque on Lamma: Project Profile June 2011
The developer of the Baroque on Lamma, BoL Limited, has submitted further information to the Environmental Protection Department. As a result, the public inspection period for the EIA project profile for this project has been restarted from 16th June 2011 and will run until 29th June 2011.
The developer refers to a letter dated 23rd May 2011 from the Environmental Protection Department requesting further information about the project profile. Living Lamma has guessed at the areas of enquiry from the responses given by the developer. These include:
- Concerns about the sewerage treatment facilities,
- Questions about alterations to the terrain,
- Details relating to the breakwater and its pilings,
- Concerns about the environmental impact of Government provided utilities required but not covered by the proposal,
- Discussion of a passenger ferry service not previously mentioned,
- Details about the number of vehicles expected,
- Questions on proposed ‘environmental activities’ like eco-walks and yachting regattas,
- A question about why the helipad is not considered as part of the project, and
- Concerns over whether the project should be considered Urban Development.
Living Lamma has already submitted a paper dated 23rd May in response to the initial EIA project profile. The objections raised in that paper are still valid and we resubmit that that paper to the Environmental Protection Department in the current inspection period.
In addition, we would also like to comment on the specific areas of concern outlined in the BoL’s letter to the Environmental Protection Department of 10th June 2011, as follows:
- 1. SEWERAGE TREATMENT FACILITIES
The ecology and landscape of South Lamma is too sensitive for the proposed development to be acceptable. There are currently no sewerage treatment facilities that are suitable to support a development of this size. The few houses that are in the area have septic tanks. The disruption caused by the installation of a sewerage system (including main pipes and arteries, a treatment plant, outfall pipe and, possibly, pumping stations) would in itself destroy the landscape value of the area and have a devastating effect on the ecology. Similarly, all other utilities to support the hotel, marina and 900 flats have to be provided.
Lamma has witnessed the amount of waste and disruption such projects generate with the ongoing installation of the sewerage system in Yung Shue Wan and Sok Kwu Wan, as well as the upgrading of the water system. It is inconceivable that the destruction to the natural landscape from such activities can be mitigated in any acceptable way.
2. ALTERATIONS TO THE TERRAIN
The developer’s promise to “reduce the extent of site formation by terracing” is nonsense to anyone who is familiar with South Lamma and appreciates the landscape and ecological value of the area. This area is one of Hong Kong’s environmental assets and should be protected as such, not given over to property speculation.
- 3. BREAKWATER AND PILINGS
For anyone who knows South Lamma and appreciates the natural landscape and ecology of the area, the suggestion by the developer to deface the natural shoreline (a coastal protection area) with “concrete caissons on rubble mound foundation” is completely unacceptable.
- 4. PROVISION OF UTILITIES NECESSARY TO THE DEVELOPMENT BUT OUTSIDE THE PROJECT BOUNDARY
It is unrealistic to assume that the environmental impact of this project will not affect areas outside the project boundary. The statement from BoL that, “The provision of utilities outside the project site boundary does not form part of the scope of this EIA study” is unacceptable. It is misleading for the developer to try to exclude environmental impacts that they are responsible for causing by pretending these are beyond the scope of the proposal.
- 5. PROVISION OF FERRY SERVICES
The provision of a dedicated ferry service was also made by one of the joint venture partners (King Wong) for another development on Lamma. There is no indication that this service will materialize. The development has yet to be occupied. It stands as a monument to the promises given by the developer that have failed to come to fruition. BoL is now seeking to distance itself from this project, yet it was King Wong that was responsible for the systematic buying up of agricultural land from villagers in South Lamma that made the Baroque proposal possible. The existing ferry operators servicing Lamma find it difficult to sustain their services. The Baroque’s promises cannot be substantiated.
From an environmental perspective, Lamma Island does not need additional pollution of its waters by additional ferry services.
- 6. VEHICLES ON LAMMA
The introduction of shuttle buses, taxis and private cars to Lamma runs contrary to the planning intention of the island, which states:
“The general planning intention is to conserve the natural landscape, the rural character and car-free environment of Lamma Island.”
It is ridiculous to intimate, as in the BoL’s letter to the EPD, that the damage caused by the introduction of 200 vehicles can be mitigated if these vehicles use “clean energy sources.” There can be no cleaner energy source than the feet visitors to the area currently use. Beautiful countryside trails will be replaced by roads (complete with road markings and signs), which with alter the whole character of the place.
And what of safety and policing? Hikers are not currently concerned about being knocked over by cars on their visits to South Lamma. Who would be responsible for enforcing traffic laws? Who will be allowed ownership of private cars? Why should some people be allowed ownership and not others?
- 7. PROPOSED “ENVIRONMENTAL” ACTIVITIES
For anybody who knows South Lamma and appreciates the natural landscape and ecology of the area, the suggestion by the developer that: “Eco-trail walks will be held at the existing or new footpaths along or within the proposed Conservation Corridor” is nonsense.
The area already has beautiful trails and visitors to the area do not come to view real estate. They do not have to dodge vehicles. They have unlimited, free access to unspoilt landscape where they can see nature in action. There are already youth groups, schools and nature conservationists that bring groups to the area. Most NGOs are opposed to the Baroque proposals. Only two groups: Ichthyological Society of Hong Kong and the Zoological Society of Hong Kong are listed as “Green Partners” on the BoL’s website.
Living Lamma has contacted the Ichthyological Society to ask why, when other green groups oppose the Baroque’s proposal for South Lamma, they seem to support it. We have yet to receive a response. We could find no listing for the Zoological Society of Hong Kong, so wrote to the developer to ask for the contact details. The developer said that any enquiry about the Zoological Society of Hong Kong should be addressed to the Chair of the Ichthylogical Society of Hong Kong. We are still investigating these two groups, but given that they appear to involve the same people and have been “engaged” by the developer, we are skeptical about their credentials.
Living Lamma has also approached the Royal Hong Kong Yacht Club to enquire about the suitability of South Lamma for sailing. We were told that South Lamma is generally considered unsuitable for sailing because of the sea conditions, which can be treacherous for novice sailors. There is a lack of berths in Hong Kong. However, there are other more suitable sites, with important road access, that are under consideration for conversion to boat clubs and marinas. South Lamma is not considered suitable because of its location – yachters tend to like to have car access for their equipment – and the environmental damage the project will cause.
- 8. THE PROPOSED HELIPAD
The helipad is part of the planned development and therefore should not be considered as a separate project for the purposes of the EIA.
- 9. CONSIDERATION OF THE BAROQUE AS URBAN DEVELOPMENT
The developer points out that the proposed project is on an outlying island. They fail to acknowledge that the planning intention for the island is this:
“The general planning intention is to conserve the natural landscape, the rural character and car-free environment of Lamma Island; to retain Luk Chau in its natural state; and to enhance the role of Lamma Island as a leisure destination. The ecologically and environmentally sensitive areas including the Sham Wan SSSI, the South Lamma Island SSSI, mountain uplands, woodland and the undisturbed natural coastlines should be protected.
Future growth of the settlement is limited to the existing villages and development nodes. The existing low-rise, low-density character of the traditional villages and other residential areas should be retained. Supporting Government, institution and community and open space facilities have been allowed for. Opportunities have also been provided for the enhancement of the waterfront of Yung Shue Wan and integrating recreational and visitor attractions. It is also the planning intention to preserve the cultural heritage of Lamma Island, which is one of the most ancient settlements in the territory. The heritage sites could also serve as visitor attractions to enhance the role of the island for conservation and as a leisure destination.” (Statutory Outline Zoning Plan for Lamma Island)
Living Lamma members fail to see how a plan to construct a 120-room hotel, plaza and 500-berth marina, as well as 900 flats and 135 car parking spaces on South Lamma, land that is currently zoned for agriculture, conservation and coastal protection, could possibly be allowed. It is clearly not rural development or within the parameters of the Outline Zoning Plan for Lamma. Supporting the project by granting an EIA study would make a mockery of government planning and conservation statements on Lamma and allow other sensitive areas to fall prey to speculation by real estate developers. It would also represent a waste of taxpayer’s money. We urge the EPD not to accept the EIA profile presented by the company.
Author: Jo Wilson