The HKBWS understands that the rezoning is for the conservation of the grade one historic building Carrick at 23 Coombe Road. However, we consider that nature conservation should not be sacrificed for heritage conservation, particularly when the Government has not fully explored other alternative options. The “like-for-like” land exchange for the in-situ heritage preservation at 23 Coombe Road should be kept within residential zonings of low ecological value, while the Green Belt (GB) area of moderate ecological value should be retained as a buffer between the residential area and the Aberdeen Country Park. The public consultation deadline is Wednesday (29 June), please submit your objection letter to TPB to protect the GB areas and to avoid potential cumulative impacts on the Black Kite roost at Magazine Gap!
Below are major concerns of HKBWS regarding the amendment of the OZP:
改劃地點具中度生態價值：根據早前一份植物調查報告，改劃地點擁有成熟的樹林及中度多樣性的本地植物。該處與周邊的樹林有良好的連結，並在沒有人為干擾下有潛力發展成為更成熟的樹林。改劃地點裡及附近記錄到全球易危的白桂木。 The rezoning site is of moderate ecological value: According to a previous plant survey report, the rezoning site has a mature woodland with moderate diversity of native flora. It has good linkages to adjacent woodlands and has potential to become a more mature woodland in the absence of human disturbance. Seedlings and tree specimens of the globally vulnerable Silver-back Artocarpus (Artocarpus hypargyreus) was found in and around the rezoning site.
改劃地點應保留為綠化地帶：改劃地點擁有豐富的植被，而且具中度生態價值。現時它是住宅發展及香港仔郊野公園之間的緩衝區，完全與綠化地帶的規劃意向相符。 The rezoning site should be kept as a GB zone: The rezoning site is well-vegetated and is of moderate ecological value. It currently acts as a buffer between the residential developments in the area and the Aberdeen Country Park and is entirely in line with the planning intention of the GB zone.
改劃用地的不良生態影響：由於建屋需要，建議的住宅用地需要清除植被，以致破壞了該處的生態價值及降低周邊樹林的生境質素。綠化地帶的寬度亦會縮窄，從而降低其緩衝能力。 Adverse ecological impacts of the rezoning: The proposed residential zoning would lead to vegetation removal for the construction of a new house, which destroys the ecological value of the rezoning site and reduces the habitat quality of the adjacent woodland. It would also greatly reduce the width of the GB zone, hence lowering the buffering capacity of the GB zone for the adjacent Aberdeen Country Park.
對馬己仙峽麻鷹晚棲地的關注：馬己仙峽的麻鷹(Milvus migrans)晚棲地不僅是全港最大，而且是南中國已知最大的晚棲地。我們擔憂是次改劃會為日後綠化地的發展立下不良先例，引致對具區域重要性的麻鷹晚棲地造成累積影響。 Concerns regarding the Magazine Gap Black Kite roost: The Black Kite (Milvus migrans) roost at Magazine Gap is not only the largest in Hong Kong, but also the largest known roost in southern China. We are concerned the approval of the proposed amendment of the OZP would set an undesirable precedent for future developments in the GB zones of the area, leading to cumulative impacts on the Black Kite roost of regional importance.
與綠化地帶改劃政策不相符：近年的施政報告只提出將「沒有植被、荒廢或已平整」的綠化地帶改劃，但沒有提及將有植被的綠化地改劃。我們認為是次改劃有植被的綠化地帶與近年的施政報告不相符，而且違背了綠化地帶「不應作任何發展」的原則。 Not in line with the GB rezoning policy: In recent years, the Policy Addresses only proposed to rezone GB areas which “are devegetated, deserted or formed” , but nothing was mentioned for the rezoning of vegetated GB areas. We consider the current rezoning of well-vegetated GB zone is not in line with the previous policy addresses and contradictory to the “presumption against development” of GB zones.
為決定負上責任：倘若此改劃通過，改劃申請人及支持通過改劃的城規會委員以及有關政府部門須為此決定 - 犧牲生態、地貌及靜態康樂價值等公共資產以成全私人奢華發展及成為香港非可持續發展的標誌性例子 - 負上責任。 Full responsibility for the decision made: Should this amendment be approved, both the proponent and those willing to approve the proposed amendment in the TPB and relevant Government departments and bodies must expect to be held accountable for sacrificing the public assets of ecological, landscape and passive recreational value of the site in order to facilitate a private luxury development in what will become a landmark example of unsustainable development for Hong Kong.