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

Letterhead of THE HONG KONG INSTITUTE OF ARCHITECTS

15 October 1998

The Secretary
Town Planning Board
15/F, North Point Government Offices
333 Java Road, North Point
Hong Kong

Dear Sir,

Objection to:
Draft Kai Tak (North) Outline Zone Plan No. S/K19/1
Draft Kai Tak (South) Outline Zoning Plan No. S/K21/1

On behalf of the Hong Kong Institute of Architects, we would like to lodge our objection to the Draft Kai Tak (North) Outline Zoning Plan No. S/K19/1; and the Draft Kai Tak (South) Outline Zoning Plan No. S/K21/1

The reasons for our objection are:

(1)	The extent of the reclamation (299ha) as proposed for Kowloon Bay is excessive. It has serious adverse impact on the environment, on the aesthetics and on the general well being of Victoria Harbour. If implemented, the central portion of Victoria Harbour will effectively be turned into a channel. The charm of Victoria Harbour that millions of Hong Kong residents and international tourists come to love and enjoy will be lost. It is like reclaiming part of the world famous West Lake in order to provide more land for the urban development of Hangzhou! We consider such insensitive act environmental vandalism!
(2)	There is no justifiable reasons for reclaiming the Kowloon Bay to the extent as proposed on the Kai Tak (South) Plan. Half of the proposed reclamation is used for road network (Central Kowloon Route, Road T1, T2 and their multitude of connections) and a Metropolitan Park. The design of road network is unresolved, and, if implemented in the manner as suggested, will become an urban eyesore and will blight the area for about 18 years even before any major building works commence at Kai Tak South.
(3)	The body of water in Kowloon Bay is already a natural 'open space' for the surrounding neighbourhood. This large body of water can be treated, kept cleaned and maintained as recreational water park. To reclaim this valuable section of the harbour to make way for an oversized Metropolitan Park (largest in the territory) shows a complete lack of sensitivity as well as sensibility.
(4)	The estimated total population of 320,000 people expected for the proposed "City within the City" development project right next to the already congested and rundown districts of Kowloon show a total lack of planning wisdom. This plan with such heavy concentration of population, if implemented, will no doubt extend even more heavier traffic congestion and confusion to a larger area.
(5)	We have strong reservation about the effectiveness and the wisdom of the open drainage channels shown on the Kai Tak (North) & Kai Tak (South) plans. We have grave concern of their undesirable environmental impact to the future development of the surrounding area.
(6)	We request that the Planning Department to spell out in clear planning terms the logic and objective of development control they have in mind on the areas zoned C, R(B) and R(B1) on the Kai Tak (South) Plan.
(7)	The proposed Outline Zoning Plans pay no regard to the physical presence of the existing Kai Tak runway and the physical urban fabric of the existing neighbourhood. Sensitive planning may help to integrate more sympathetically the proposed development physically and socio-economically with the existing urban development.
(8)	Our understanding is that development as shown on the proposed plan above the existing Kai Tak runway and the apron area is very difficult, if not impossible, for two major reasons: The solid rock filled foundation below the runway makes it almost impossible for piling over the runway. The soil condition of the runway and the apron area have been affected seriously by leakage of jet fuel oil accumulated over years. This area is extremely hazardous for extensive development particularly underground (basement) construction. Treatment as proposed by the consultants of the Environmental Protection Department does not seem to follow a rigorous standard. The benzene in the underground water may cause cancer. The concentration of methane in the soil is over 15% and this is a potential threat to the residents living over this area because 5% alone is sufficient to cause explosion. This plan does not attempt to resolve the problem of the existing polluted Kai Tak nullah. It appears that little, if anything, is done to resolving this major source of pollution which is being fed from the surrounding catchment area. This should be a major feature of any successful plan.
(9)	The landuse shown on the proposed plan is based on dated 2-dimensional planning approach of assembling isolated land parcels which lacks market viability and forward thinking. When fully developed, as proposed, some 18 years later, the future out look of this area will be similar to the near by characterless existing housing estates! It seems the prime objective of this landuse plan is to create isolated land parcels for land sale rather than to create a dynamic and sustainable 3-dimensioned urban organism.
(10)	There are many insensible provisions in the proposed draft Outline Zoning Plan, for example: Refuse transfer station, public filing barging point and sewage treatment plant, etc are located at the tip of the existing Kai Tak runway which is the most prominent spot - the front door of Hong Kong entering from Lei Yue Mun. The continuous waterfront promenade in the proposed plan from Hung Hom to Kwun Tong ends at the refuse transfer stations, public filling bargaining point and sewage treatment plant! This shows insensitive planning as well as total lack of appreciation of visual as well as environmental quality of waterfront urbanscope.
(11)	Road network has not been thoroughly worked out particular when interfacing with existing roads of neighborhood areas. There is also no innovative idea to deal with the relationship between people and cars within the proposed planning area. This should be an important issue to be addressed when planning for the future.
(12)	The proposed scheme projects neither a visionary nor a dramatic Hong Kong Waterfront image of Victoria Harbour which Hong Kong badly needs.

We would be very happy to elaborate on the points of our objection to the two Draft Outline Zoning Plans to members of the Town Planning Board when requested.

We believe development in this area deserves a more humanistic and forward thinking approach setting an inspiring example of how SAR respects urban ecology in shaping a sustainable waterfront development in the Third Millennium. The planning of the Kai Tak area should reflect the Hong Kong SAR Government's latest commitment to support the idea of Sustainable Development.

Thank you for your attention.

Yours faithfully,


Dr Tao Ho
President HKIA

cc

The Hon Mr C H Tung, Chief Executive The Hon Mrs A Chan, JP, Chief Secretary for Administration The Hon D Y K Tsang, JP, Financial Secretary Mr S S K Ip, JP, Secretary for Economic Services Mr B Leung, JP, Secretary for Planning, Environment and Lands Mr N W F Ng, JP, Secretary for Transport Mr H S Kwong, JP, Secretary for Works Bureau Mr G Siu, JP, Head, Central Policy Unit Dr P K S Pun, Director of Planning Mr S S Lee, JP, Director of Territory Development Department Mr R J S Law, JP, Director of Environmental Protection Secretary of Executive Council (to be distributed to the Councilors) Secretary of the Legislative Council (to be distributed to the Councilors)