Not really; Kam Ho Road got `=secondary` with precedent (see me trying to demote Old Clear Water Bay Road to `=tertiary` with no success); Kam Sheung Road Station wants strong alternative route to access Route 3.

I think Tung Hui Road is not as important. The new park-and-ride needs the `=primary` section for entrance, and depending on exact destination, exiting  might just make sense to go through Kam Tin Bypass or Pat Heung Road.

Actually, also consider e.g. San Tam Road is "only `=tertiary` when Castle Peak Road is `=secondary`"; feels like a good analogy/perspective for this case.