Building Height Restriction -KwunTong & Kowloon Bay (June 2004)

The HKIP supports the principles to protect the ridgelines of Hong Kong, which is a natural asset treasured by Hong Kong people and of which a general public consensus has been reached during the Urban Design Guidelines for Hong Kong Study. We appreciate Government's pro-active effort to review building height profiles of the Kwun Tong and Kowloon Bay business areas, with a view to ultimately translating them into more effective statutory controls. We however, wish to raise the following comments to allow better urban design of these two business industrial areas:

The Institute is of the opinion that in addition to height controls, controls on other aspects of urban design should also be considered in the review and included in the recommendations. These should include site coverage controls, a greater variation in the proposed building height bands, control over the building design for large sites at the waterfront etc. Moreover, we are of the opinion that it is not necessary for the review to allow for blanket relaxation of building height on sites that are subject to more stringent height restrictions under the lease.

We believe that better urban design could be achieved by a good balance of incentives and control. Whilst building height bands are recommended, it would still be necessary to retain some flexibility for designers of the development. In this regard, we note and agree to Government's intention to include a minor relaxation clause in the OU(B) zone. Government should also consider providing incentives to encourage designs that could improve the local environment, for example, setting back of building facades to create better streetscape, providing gaps between building blocks to improve daylight penetration and /or air ventilation etc. Gains in improvement in the local environment should of course be weighted against its impact on the ridgelines and the possible precedent effects.

To convey a better understanding of the recommended building height controls, Government should spell out clearly about the design constraints inherent in these two industrial areas, e.g. multiple ownership, narrow site frontage, high development intensity, limited building set back etc. Other than the Quarry Bay Park vantage point, Sau Mau Ping and Shun Lee were selected as inland viewpoints to assess the impacts of building height control. It is necessary to explain the rationale for selecting these viewpoints and who would benefit from implementing such controls. These additional information would provide a better common ground for discussion.

In order to attain more effective and an overall control on building heights and design of developments in these two areas, Government should adopt a comprehensive approach to implementing urban design controls. Other than those under the remit of planning over S16 applications and land use zonings, design controls for ridgelines protection should be implemented in tandem through lease conditions and in building plan approval process.

We support Government to continue to or even expedite reviews of other relevant OZPs so that height controls could be formulated and implemented in a timely manner. Particularly, it should take into consideration the future urban design intentions of the SE Kowloon Reclamation. With the development of the old Kai Tak Airport, the waterfront landscape quality of SE Kowloon will change significantly. Opportunities for a more coordinated set of design controls have been missed when the airport height restrictions were being relaxed in 1998. Taller and taller developments are eating away our ridgelines, and the concerted efforts of Government would help the community to win this race against time.

Public Affairs Committee

Hong Kong Institute of Planners

June 2004