Democratic Party’s comments on the "Long Term Housing Strategy"—— the part on planning

10 January 1997


The Government’s inaccurate projection of the population growth had led it into committing a planning error. It is estimated that by 2001/2002 - 2003/2004, there will be a shortfall of 50 000 public and private housing flats. Moreover, with the significant population growth in the territory, it is necessary for the Government to expedite the process of building housing units and increase the supply of housing units.

Existing problems

A. The excessively long lead period for the construction of public and private housing

For public housing programmes, the whole process from planning to the completion of the construction works takes 62 months, during which the departments concerned will:

Duration (months)

a) conduct feasibility study and prepare a planning outline; the Government will then proceed with the overall planning, and the plan will be submitted to the Land Development Policy Committee for approval;


b) prepare construction blueprints, design outline and project estimates, and then submit these documents to the Building Committee of the Housing Authority (the "HA") for approval;


c) prepare design proposals and project cost estimates, and then submit these documents to the Building Committee of the HA for approval;


d) prepare a detailed design plan, and then submit it to the Project Design Review Committee for approval;


e) the project will invite tenders, and the Building Committee will examine the tenders and then award the contracts to the successful tenderers;


f) completion of construction work.


The whole process takes 62 months. However, as far as we understand, some of the abovementioned procedures, namely, phases 2, 3 and 4 are done internally by the Housing Department (the "HD"). Moreover, since the HD will adopt the same standard design for building housing estates, thus in theory, it should not take 15 months to prepare blueprints and design outline, etc.

As for private housing, the whole process from the commencement of construction work at the site to the completion of a building takes at least 39 months. The process includes a study of the outline plan(a feasibility study), which takes 18 months. Private developers think that the process takes so long for the following reasons:

  1. The main reason is a shortage of manpower on the part of the Government to examine the plans submitted by developers. So what usually happen is: the Government rejects the plans submitted by the developers one or two days before the due date for a reply to be given, and asks them to submit a new proposal instead;

  2. Different Government departments have different concerns, and they may have different views on the same plan, yet no policy branch can make a final decision;

  3. On appeals against land premiums, there is no stipulation specifying a time limit for finishing the appeal procedures, hence any controversy arising from the problem of land premium may result in delay ;

  4. Developers are required to follow Hong Kong Planning Standards & Guidelines. However, such guidelines may contradict with developers’ interests in designing the buildings into ones which will enjoy the best market value (such as designing the building into one that has an excellent seaview). Therefore, developers would keep revising the plan so as to get approvals from all relevant departments such as the Environmental Protection Department and the Planning Department. Sometimes, developers may, for commercial reasons, design the building in a way to enable it to have a better view. For example, all the windows of the building are designed to face the sea. But if this does not compile with the requirements of the Environment Protection Department (for example, the residents there are affected by noise of a level higher than 70 dB), developers will then keep on revising the plan in order to be able to sell the flats for better prices. They try to strive for their best commercial interests on the one hand, and then still be able to follow the planning guidelines. In this connection, if the developers do not agree with the decision made by the departments concerned, they may keep on revising their plans until they are granted approval. As the plans submitted would have to go to/from the developers and Government departments for some time, the completion date of the building concerned will usually be delayed as a result. Besides, given the criteria adopted by the Planning Department in respect of the appearance of buildings varies with cases, it is difficult for the developers to understand the criteria for approval. As such, they will keep on submitting new plans, which further lengthen the time for approval;

  5. The Government may exert control on the visual outlook of private buildings, for example its colour, the type of plant to be planted, the kind of tiles to be used for the podium, etc., In the viewpoint of urban landscape, the Government considered it necessary to control items relating to the outlook of buildings. If developers and the Government have different views on such matter, arguments on this matter will drag on, and will again lengthen the time for granting approval; and

  6. Despite the fact that some Government departments are very experienced in examining plans, it still takes them six months’ time to complete the whole process of granting approval. In this connection, the developers worry that when the Government introduces a new legislation (for example the Environmental Impact Assessment Bill and the legislation on Planning Certificate) in future, these departments will take even longer time to examine the building plans submitted to see if they comply with the provisions of the legislation as they will have less experience in these new legislations,

It takes a minimum time of 60 months between a developer is first granted a piece of land for construction and the building is completed if it involved planning applications. If further problems are encountered, the construction work could as long as 97 months.

In theory, the chance of having a delay by the HA in getting approval of their development plans due to a lack of manpower in Government departments should be lower than that of private developers. Besides, as the HA adopts a standard design for all housing estates, the time spent on housing design should be, theoretically, shorter than that of private developers. Yet, the HA has to spend 15 months on housing design and the relevant approval procedures, which can be completed by private developers in a few months. On the other hand, it is noted from the previous experience of private developers, that the main reason for the extended time used in the approving procedure is a lack of manpower in Government departments, or because, in accordance with the procedure, the plans submitted by developers have to go through different departments at different stages for examination. If these procedures can be improved, the time required for housing production can be shortened.

B. Lack of coordination in planning leads to delayed completion of building programmes

I. Public Housing

Even if the HA was granted land for development, sometimes the construction work had to hold up because supporting infrastructure (like roads) or other social facilities (like schools) in the neighboring area were not ready. The lack of coordination in social facilities may be a result of the Government’s inaccurate projection of population growth. For example, the Government estimates that there are insufficient children at schooling age in the area to justify the building of schools there. But after the housing estates is completed, it turned out that the numbers of such kind of children are too many, so they all had to turn to schools outside the area. Sometimes, the Government may decide to build housing units only after schools and roads have already built in the area. Such lack of coordination in planning will result in delay in building construction work.

Besides, difficulties will be encountered in the redevelopment of housing estates,(for example residents living in the redevelopment area are reluctant to move out) this would hinder the demolition work in those old housing estates, and which in turn postpone the completion date of new housing.

II. Private Housing

In respect of private housing, in order to obtain the letter of compliance and occupation permit, developers must comply with the requirements of all the departments concerned. Regarding planning, the requirements sometimes involve other land development works and demolition programmes, which are outside the scope of developers, and in most cases, it is the Government who should be held responsible (such as the demolition of squatters). Nevertheless, these external factors would all affect the completion date of the housing production programmes. We consider that if the Government requires the provision of certain package facilities (such as bridges and private roads) by developers when the construction work is completed, whereas the building of such facilities is related to other construction works carried out by the Government, then the Government should accord a higher priority to these works, so as to ensure that the private flats could be completed as early as possible.

Besides, in the past, if the Government did not have sufficient capital to provide supporting infrastructure for the adjacent private housing estates, developers would propose to build certain facilities (like private roads and bridges) as conditions for getting approvals from the Government for housing production. However, if the supporting infrastructure linking the bridge is to be provided by the Government, and yet the timing of planning for the provision of such infrastructure could not completely cope with the need of housing production (in some cases, this is due to a lack of capital on the part of the Government departments). In that case, the completion date of the housing production programme will be directly affected. For example, if one of the conditions for the Government’s approval of the developers’ request for housing production, was the provision of a footbridge linking the road on the opposite side, yet the construction work of that road is to be done by the Government. so if the Government could not complete the construction work on time, the completion date of the housing programme would be affected.

C. Plot ratio of public housing

1 It is quite common that the HA could not fully utilize the plot ratio when developing public housing. From the paper submitted by the HD to the LegCo Panel on Housing, it held that the reason for its failure to fully utilize the plot ratio is the restriction imposed by certain particular environmental factors. In other words, if the immediate area outside the private housing estate is compared to that of public housing estate, it is found that the latter is much more spacious. This is attributable to the design of HA’s housing estates. Private developers usually build highly intensive housing estates, using the smallest amount of land to build the largest number of residential flats. For example, private developers will use the basement as carpark; the ground floor and the first floor as shopping arcade, and the second floor as podium and main entrance. On the other hand, the HA will put the carpark, recreational ground and living area in various places of the housing estates, but all are on the ground floor. Such a design enables the residents there to have more space to move around. But for land with the same area, the number of people that could be housed by estates built by the HA will be smaller. Given the abundant resources available for use (i.e. there is sufficient land and flats to house the people in need), this should be an ideal design, which gives residents a more spacious environment. However, as there are at least 500 000 people in the territory who are inadequately housed, it is important to strike a balance between the space residents may enjoy and the need to house more people.

2. Besides, since all the housing production are required to undergo environmental impact assessment process now. For example, housing estates built by the public and private sectors have to ensure that residents are free from noise disturbances (noise level should be lower than 70 dB), therefore, developers should try to separate the housing estates from the roads or other environment which create noise disturbances. For private developers, they would build a barrier extending from the podium so as to shield off the noise. However, the HA would separate the housing estates a certain distance away from the road, using this zone as a restrictive noise barrier. Such a zone is about 20 to 30 meters wide (depending on the situation). Noise restrictions on public rental housing estates are tighter than those of HOS estates. The HD’s explanation is: residents of private housing and HOS estates can afford to install air-conditioners, while that of public rental housing cannot. Firstly, since it is the design of HD to have recreational ground of housing estates located on the ground floor (unlike private housing, which usually have their podium located on the second or third floor), therefore, if developers have to comply with the noise protection standard set by the EPD, they cannot follow the practice of private developers, i.e. extending a barrier from the podium to shield off noise. After all, the design adopted by the HD for housing estates is the standard design, so it lacks flexibility. It will not change to suit the different environments for different types of buildings. On the premise of complying with the noise standards of the EPD, the HD will waste a lot of land.

3. Land with a smaller area or located on slopes cannot be used

Since the HD adopted standard design for all housing estates, land with a smaller area or located on slopes cannot be used. On the other hand, private developers will have different design of buildings for different geographical conditions. For example, an entire private housing estate has been built on a slope. We consider that the HA should adopt different designs for various types of housing to fit into different sites, so that the whole site can be fully utilized.


I. Construction period for public and private housing

1. It is mentioned above that the construction period for public and private housing are excessively long because the Government had spent too much time on the examination and planning procedures. Regarding the procedures of examination and design of public housing estates, since the HD adopt standard design for all estates, it is odd that it has to spend six months on completing the design procedure. Regarding the approving procedure, since the whole process is done internally, so the required time of 15 months for completing the design and approving procedures is too long. We suggest that the HD should study measures that would streamline its internal approving procedure in order to expedite the approval of housing production programmes.

  1. Regarding private housing estates, as the approving procedures requires the submitted plans to go through nine Government departments, so we suggest that those departments concerned should work on the procedure at the same time as far as possible in order to save time. Besides, since there is a lack of manpower to work on the approving procedures of housing estates, we suggest the Government should deploy more manpower to approve building plans.

  2. Since some Government departments have very complicated requirements in approving plans for private housing programmes, it is difficult for the developers to grasp their requirements. Therefore, we suggest that the departments concerned should lay down concrete guidelines for developers to follow.

  3. Besides factors such as environmental protection and planning, and the fact that certain areas have been designated as protected zones, we consider that the Government should not interfere with aspects related to the visual outlook of buildings.

II. Planning Package

  1. There is a lack of coordination on the part of the Government in planning. This includes: the timing for the provision of facilities in the neighboring areas cannot match with the completion date of housing production programmes; or such programmes being shelved because of a lack of capital. We suggest that, in view of an acute shortage of housing supply, if the Government does not have enough money to start on the programmes, the Legislative Council should set aside money for the provision of supporting infrastructure in respect of housing production. (Even though the HA or developers are willing to pay for the expenditure on building supporting infrastructure for the Government, the Government will not prefer such an arrangement because this involves the payment of interest and complicated accounting procedures).

  2. Regarding the Government, it should establish a coordination system: when there is a conflict of requirements for developers between different departments, the policy branch concerned should make the final decision. The Government should also appoint a senior official to handle these matters, so that whenever conflict of requirements for developers arises between departments, the responsible policy secretary can handle the problem right away.

  3. We suggest that Government departments should lay down performance pledges concerning the approving time limit, so as to ensure the layout plans and programmes of the developers can be examined within a reasonable period of time.

  4. The Government should make periodic reports on the various departments’ approval time to the Legislative Council; and if the approval time of plans of any department completion is longer than the specified time limit set out in the performance pledge or the average time that is required to approve a plan, it has to explain to the LegCo the underlying reasons for such a delay.

III. Full utilization of land

  1. It is mentioned above that as the HA adopted standard design for all estates, thus its choice of land for building housing estates is limited. Since the supply of land in the territory becomes fewer and fewer, thus the HA must fight for every inch of land, even land with smaller areas should be considered for housing production. To achieve this end, the HA should design different types of estates on different sites according to their specific geographical conditions, so that the plot ratio can be fully utilized. For example, the HA can model on the design of private housing to build carparks and shopping arcade on the ground floor, using the podium as recreational ground, and the above floors for living purpose. Besides, in order to make residents free from noise disturbance, the Government can make reference to the housing design of private developers, i.e. to erect a noise barrier extending from the podium, or to build tunnels instead of roads.

  2. In areas which are no longer suitable for industrial development, the Government should change their land use and designate them for residential purpose as early as possible.

Last Updated on 20 August 1998