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

Letterhead of THE CENTRE OF URBAN PLANNING & ENVIRONMENTAL MANAGEMENT

16/10/98

Miss Odelia Leung
Clerk to Panel
LegCo Panel on Planning, Lands & Works
Legislative Council, Central, Hong Kong
Fax 2877-8024

Dear Ms Leung:

We the undersigned of the Centre of Urban Planning and Environmental Management of The University of Hong Kong appreciate the opportunity to comment to the Panel on the South East Kowloon Development.

As the attached statement notes, we feel that it is vital for the Panel to closely examine the proposed development as reflected in the gazetted draft Outline Zoning Plans (OZPs) for Phases I and II and the published design drawings for the full development.

We feel that the process by which the plans were drawn up is fundamentally flawed with regard to public participation and that perhaps as a consequence, the proposed plans are poorly conceived and would, if implemented, detract from rather than add to the quality of urban Hong Kong. Where the Kai Tak redevelopment offers a major opportunity for a new vision for the SAR, the design plans fail to convey a vision for Hong Kong to move forward into the 21st century. We find the use of the use of-waterfront especially inappropriate and the juxtaposition of incompatible land uses highly problematic. We detail these points in the attached paper.

Sincerely,

William Barron, PhD	_______________	Roger C.K. Chan, Ph.D.	_______________
Allison Cook,	_______________	Prof. Peter Hills	_______________
Ng Mee Kam, PhD	_______________	Prof. A.G.O. Yeh	_______________

We feel that the proposed SE Kowloon Development as shown in the draft Outline Zoning Plans (OZPs) for Phases I and II (which covers the old airport site) and the published design for all four phases (i.e., including the Kowloon Bay reclamation) were developed through a seriously flawed process and the designs themselves (as reflected in the materials published so far) would detract rather than add to the goal of making Hong Kong a better place for our people and visitors. These points are explained and elaborated below.

A FLAWED PROCESS

First, we note that it is difficult to comment on the draft OZPs for Phases I and II when no firm decisions have been made on Phases III and IV. Decisions about Phases I and II could well restrict options for III and IV. For example, if the OZPs for I and II are approved, how much flexibility remains with regard to the extent and shape of reclamation, the number and types of flats, the balance of different types of land uses, and alternative uses for particular areas?

Plans for major developments should express a clear vision for the proposal within the context of overall territorial development. These plans should also make specific the particular issues and problems they are intended to address. Unfortunately, the information released by government (in both Chinese and English) in this case is woefully inadequate in this regard.

The process by which these OZPs and the overall design have been brought forward seems to have been turned upside down. In principle, a good planning process involves several clear steps: (i) identification of the broad development concerns and problems, (ii) bringing together the community to discuss these broad issues, (iii) in light of the community's input, development by government of detailed alternative plans, each with its pros an cons as seen by government clearly stated, along with an explicit set of criteria by which the alternative designs are to evaluated, and finally (iv) an opportunity for the community to comment on the alternatives before one of these is selected.

Instead of a good planing process, what the government has done in this case (as in so many others) is to bring out a single plan already developed in each of its major features without any evidence that comments from those outside government have been sought or even considered if they are put forward independently. In the case at hand the apparent absence of a willingness to even acknowledge the ideas of others (see below) is shocking.

A DESIGN FOR YESTERDAY NOT TOMORROW

As this point we can only assume that the published general plan drawing for the whole of the development is the government's preferred one and here we comment on that design.

Far from being a vision for the next century, the published design for the SE Kowloon development reflects discredited approaches from the past in which road transport is given the highest priority, the harbour is seen simply as a cheap way to create land, housing estate layout is merely utilitarian, and open space and amenities are after-thoughts to be accommodated in spaces inconvenient for other uses.

It happens that the Kai Tak redevelopment was the subject of preliminary design investigations and suggestions by the Hong Kong Institute of Architects and participants in Designing Hong Kong (an informal group of architects, lawyers, urban planners, and ordinary citizens) in 1997 and early 1998. The offered designs, while preliminary, demonstrated the wide variety of ways the SE Kowloon development could meet housing and road needs, while minimizing the extent of reclamation, maximizing the attractiveness of the waterfront, and designing a high quality of urban life (e.g., with respect to minimal exposure to air pollution and noise, designs to facilitate social interactions, etc.). In contrast, government's published design reflects none of these suggestions and indeed is unimaginative and inadequately thought-out.

We briefly list here just a few specifics of our concerns about the government design.

The design maximizes reclamation and produces a nearly straight waterfront.

This approach not only minimizes the interface between the land and the water, it makes the interface uninteresting. Further, the plan shows only a thin line for a promenade along the waterfront. Immediately behind it the land is devoted to non-amenity uses. In striking contrast, the deeply curved waterfront around a small bay surrounded by a boating/restaurant area as suggested by the HK Institute of Architects is far superior in each of these respects.

The government plan looks like a mockery to the government's claimed endeavour "to bring the harbour to the people and the people to the harbour"

The major environmental amenity, the central park, is surrounded by highways which generate considerable air pollution and noise.

Indeed, the location of the park seems to be mostly a matter of finding some low-valued use for this otherwise dead space between the roads. Worse still, the roads themselves are surrounded by tall buildings which minimize air circulation and further lower the quality of the environment for the local residents and visitors to the park.

The primary purpose of the reclamation seems to be to accommodate roads.

Roads directly and indirectly (e.g., buffer areas) account for about 40% of the total land area. Roads are necessary but is giving them such priority at the dawn of the next millennium appropriate?

The opportunity to provide a truly visionary start on the next millennium in the heart of the city and the Victoria Harbour will be lost if the government's design goes ahead.

A well designed SE Kowloon development could provide much needed harbour amenities for Hong Kong people and to tourists. It could demonstrate how to move to toward more sustainable transport by focussing on rail and pedestrianization. and the use of good urban planning practices and building designs to maximize the quality of life for local residents, and promote good building design could through carefully structured incentives to developers.

To conclude, we recognize that Hong Kong needs land and that redevelopment of the Kai Tak site must provide badly needed housing and infrastructure. However, we are confident that such needs can be met through alternative designs which make far better use of the waterfront and make the whole of development area something which reflects what Hong Kong truly can be as a leading city of the 21st century. It would be a great misfortune to let that opportunity pass by.