CB (1) 353/98-99 (01) (b)


Our Ref:GJO/cyn/98.305/KT-10

20 October, 1998

The Secretary,
Town Planning Board
C/o Planning Department
23/F North Point Government Offices
333 Java Road
North Point
Hong Kong.

Dear Sir,

Re:1.Kowloon Planning Area No.19
Draft Kai Tak (North) Outline Zoning Plan No S/K19/1

2.Kowloon Planning Area No.21
Draft Kai Tak (South) Outline Zoning Plan No S/K21/1

The relocation of Kai Tak airport has provided Hong Kong with a unique opportunity for urban development on a massive scale and it is essential that this opportunity is not lost through a lack of imagination or administrative expedience. It is the view of the Hong Kong Institute of Surveyors (HKIS) that the Kai Tak area should be planned as a single entity and for this reason we have considered the captioned plans together and have not attempted to limit any particular reason for objection to either specific plan.

The Hong Kong Institute of Surveyors fully supported the Protection of the Harbour Ordinance 1997 and remains committed to the view that our harbour is a unique asset which should be preserved as far as is possible for future generations to enjoy.

Although this South East Kowloon reclamation will fall outside the Central Harbour area the HKIS is of the view that the principle of conserving the harbour as far as is possible should be the prime objective by ensuring that the minimum rather than the maximum area of reclamation is proposed.

We have therefore set out a number of key points which we believe the Board and Government should address prior to preparing a revised plan.

1. The Provision of a Mass Transit Rail System.

The HKIS believes that the provision of a comprehensive mass transit rail system is an essential requirement for an urban development of this scale. The rail system should be implemented as an integral element of the infrastructure. Hong Kong people place a high value on travel convenience and to make no mention, and presumably therefore no provision for a rail system is completely unacceptable.

The environmental benefits of less roads, less buses, less bus termini, less noise and less air pollution are sufficient justification for a rail system even ignoring the economic benefits that will be created by such a provision.

We note that despite there being no reference to any rail system in either plan, there is a CDA zone on Plan S/K 19/1, for a private residential development above a railway depot. If a depot is required then the alignment of the railway, which will necessitate the depot, should be shown on the plans to enable a full evaluation of the plans to take place. The confusion created with the CDA zoning raises serious concern as to the credibility of the entire plans.

2. The Development Potential.

The plot ratio restrictions of 6.5 for domestic buildings and 7.5 for non domestic buildings are inappropriate for a newly planned central urban area. With proper infrastructure the plot ratios should be the maximum achievable under the Building Planning Regulations. One clear advantage of fully utilizing newly formed sites will be the ability to reduce the extent of reclamation required to achieve the same level of gross floor area.

3. Commercial Zones.

There appears to be no logic for the designation of commercial sites. If the intention is to create a new decentralized office zone then it should be concentrated over and adjacent to a railway station. A review of the more successful decentralized areas will clearly illustrate the market preference for easy access to a rail system.

With the extent of obsolete industrial areas which are suitable for conversion to office use and the recent changes in demand for offices there is a strong argument for reviewing the need for any sites to be zoned specifically for commercial use. The HKIS believes that within an overall planning framework market forces should determine land use and therefore recommends the adoption of a C/R zone to allow sites to be developed to their optimum use.

4. Residential Zones

The explanatory statements for both plans state that the majority of the sites under this zoning are to be reserved for either public rental housing, Home Ownership Schemes or Private Sector Participation Scheme. In the North Plan only 2 sites have been zoned for private housing. This represents a gross imbalance between public and private housing provision. In the prevailing market conditions coupled with the comments contained in this years policy address this residential mix will require a complete rethink.

5. Industrial

There is an abundant supply of industrial land in Hong Kong for which there is little if any demand. The recent rezoning of industrial land to other uses in planning areas adjacent to Kai Tak is evidence of Government's recognition of this fact. It is therefore surprising to see sites within the subject plans being zoned for industrial use.

An explanation of the apparent contradiction between providing sites for industrial development in Kai Tak whilst at the same time deleting land for industrial use in Ma Tau Kok and Yau Tong Bay is required.

6. Provision of Open Space.

We have strong reservations about the need to reclaim large areas of the harbour for open space purposes. The harbour cannot be replaced and already fulfills a valuable "open space" function. The value of another urban park particularly one surrounded by such an extensive road system is questionable.

7. The Proposed Road System.

The provision for roads of all categories utilizes a large proportion of the total area of both plans. The extent of such provision needs full justification, and a comparison with the road system that would be required if a rail system is provided as an integral part of this plan should be published for the community to judge. At present the plans appear to have been prepared by traffic engineers.

For these reasons we cannot accept that these plans represent either the best or optimum layouts for this crucial area of urban Hong Kong. Once again Government appears to be adopting the quick fix solution of extensive reclamation without giving full consideration to the long term consequences of its plans in terms of urban design, environmental quality or even basic economics.

We therefore strongly object to these two draft plans.

Yours faithfully

T.N. Wong
Hong Kong Institute of Surveyors