HKIP Comments on Chief Executive’s Policy Address 2019
HKIP’s comments and suggestions on the 2019 Policy Address are as follows:
General Comments
While we appreciate the commitment of the Government to increase land supply with clear targets in the Policy Address, we do have great concern on the intended departure from the government-led comprehensive and equitable town planning regime with respect to the proposed Land Sharing Pilot Scheme (LSPS) and the singling out of brownfield sites. We are worried that such scattered and uncoordinated developments would result in isolated public housing developments without the needed transport and social infrastructure as well as employment opportunities for the future residents.
Without comprehensive planning, the optimum use of the surrounding land resources may be jeopardised in future developments. Resumption of land of small owners for infrastructure to support developments by big owners under LSPS could well be challenged on grounds of equity. Expediency has a high price to pay and may not turn out to be faster.
We think a better way forward is to expedite the planning and implementation of the new development areas previously identified such as Yuen Long South, Ping Che, Ta Kwu Leng, Kam Tin East.
Specific Comments:
A. Land Sharing Pilot Scheme (LSPS)
While this new initiative seems to be an expedient mean for increasing housing land supply, we have concerns on its implementation aspects. Most private agriculture land in particular those not within areas covered by Government’s development area studies for intended public purposes are likely not supported by transportation and infrastructure networks as well as planned community facilities. The Government may need to invoke relevant legislation and resources to resume other private land for such infrastructure and road works as well as community facilities to complement the proposed development under the Scheme. This may give rise to equity problem in the resumption process if there is not an agreed planning framework under the current planning system and mechanism to justify the land use decisions and hence the land resumption. For example, there could be many alternatives for a road alignment and it is hard to justify the choice of any routing without a holistic plan, and this would lead to well justified objections to the proposal.
In order to avoid the equity problem, no resumption of small owners’ private land should be involved. The Government should also give thought on how to make the setting up and operation of the Panel of Advisors transparent and accountable to the public. Under the proposed LSPS, information on applications received, progress of each case, as well as key details of the lease modification including land premium payable would be made known to the public, which is commendable and would help to uphold LSPS’s transparency. To build trust in the community, there is also a genuine need for Government to publicise a set of well-defined criteria and guidelines for assessing such applications by the Panel, as well as the views of the Panel. Lastly, established town planning process must be followed, and the Town Planning Board should scrutinise all proposals under LSPS and genuine public objection process should be observed.
To further refine the Gross Floor Area 7:3 requirements under LSPS, we recommend that the Panel of Advisors should also specify the minimum land area for public housing development in each application so as to allow a reasonable optimal layout design for both the public and private developments within the land shared.
B. Brownfield Sites
We strongly advise that comprehensive planning studies should be conducted on meaningful areas which cover both brownfield sites and their adjacent areas. This will ensure the optimal use of land resources as a whole, and a well planned and cost-effective provision of physical and social infrastructure. We trust that the Government would properly address the implications on the economy and employment for closing brownfield storage/workshop operations, and take care of their re-provisioning needs at suitable sites with a more economical use of land.
C. Lantau Tomorrow
We support in principle the early commencement of the feasibility study of Lantau Tomorrow Vision. Comprehensive planning and engineering feasibility studies should be undertaken before making a decision on the extent of reclamation and programming. Amongst other technical concerns, the impact of extreme weather on coastal areas of the future reclaimed islands and the ecological impact during and after reclamation must be duly examined and addressed. We have reservation on the “engineering-led” approach. People-first should be of utmost importance to our Lantau Tomorrow. The cost effectiveness of reclamation options, such as reclaiming a single island or several smaller islands, should be carefully examined in the study. The public should be engaged appropriately and timely on the Lantau Tomorrow proposals. The development sequence of the future railway under the Railway Development Strategy and highway network connecting to the main urban area and New Territories is a fundamental issue to be addressed in the planning of Lantau Tomorrow. Our views expressed in our submission on 11 March 2019 to the Government on the scope of the feasibility study of Lantau Tomorrow are still valid.
D. Railway Development Strategy
We consider that the current railway development strategy appears to be largely commercially driven such that some newly proposed MTR lines (such as the Northern Link and North Island Line) that could benefit the longer term Hong Kong’s development but may not be commercially viable tend to remain just lines on the plans. There is a need to revisit the railway development program with a view to taking forward railway developments timely to tally with the population intake, so as to meet the local needs, even though we may face a deficit in the early phases of the development.
E. Other Suggestions on Land Supply Policy
As we voiced out in our position paper on Land Supply for Hong Kong in August 2018, the Government should consider establishing a Land Supply Commission comprising members from different social sectors to accelerate and monitor land supply progress. The Commission can be tasked to regularly review the rolling land supply programme in short, medium and long term prepared by the Government. The Commission could also facilitate public engagement, consensus building, and transparency enhancement on land supply issues, and hence to foster the political will for the long term interests of Hong Kong. We look forward to the Government’s favorable consideration on this in near future.
Public Affairs Committee
The Hong Kong Institute of Planners
December 2019